FRENCH v. COMMISSIONER

Memorandum Opinion

HALL, Judge:

This case is before the Court on petitioner's and respondent's motions for summary judgment filed pursuant to Rule 121, Tax Court Rules of Practice and Procedure.

Respondent, in his notice of deficiency issued to petitioner and his wife, determined deficiencies and an addition to tax for negligence as follows:

                                     Addition to Tax
  Year           Deficiency         under...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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