Memorandum Opinion
GOFFE, Judge:
This case is before us on petitioner's motion for summary judgment. Respondent opposed the motion by written response and a hearing was held on the motion in New York City.
The Commissioner determined a deficiency in petitioner's income tax liability for the taxable year 1965 in the amount of $54,731 and additions to tax under the provisions of sections 6653(b) and...
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