Memorandum Opinion
GOFFE, Judge:
This case is before us on petitioners' motion for summary judgment. Respondent filed an objection to the motion and a memorandum of points and authorities in support of his motion. A hearing on the motion was held on February 25, 1980 at Los Angeles, California.
The Commissioner determined a deficiency of $4,300.97 in petitioners' Federal income tax for their taxable year 1975, and assessed a negligence penalty of...
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