Memorandum Opinion
DRENNEN, Judge:
Respondent determined a deficiency in petitioner's income tax for 1975 in the amount of $13,500. Petitioner filed a timely petition in this Court and respondent filed his answer. Respondent then filed a Motion for Judgment on the Pleadings and petitioner also filed a Motion for Judgment on the Pleadings. When the case was called for argument on the two motions the parties filed a stipulation of all the relevant facts. After...
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