Memorandum Opinion
NIMS, Judge:
This case is before the Court on respondent's motion for summary judgment filed pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
For the year 1977, respondent determined the following deficiency and additions to tax:
Deficiency Sec. 6651(a) Sec. 6653(a)1 $46,762 $11,690 $2,338
At the time petitioner filed a petition in...
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