OPINION
DAWSON, Judge:
Respondent determined a deficiency of $22.78 in petitioners' Federal income tax for the calendar year 1975.
This matter is before the Court on a motion for summary judgment filed by petitioners April 7, 1977, pursuant to the provisions of Rule 121, Tax Court Rules of Practice and Procedure. The parties agreed to submit the motion for decision without oral argument. Accordingly...
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