Memorandum Opinion
RAUM, Judge:
On July 26, 1982, the respondent moved for summary judgment against petitioners. A hearing was held on that motion at Boston, Massachusetts, on October 18, 1982, after due notice to the parties. Petitioners did not appear at that hearing either in person or by a representative. The respondent had determined a deficiency in income tax against petitioner John C. Cincotti for 1975 in the amount of $2,744.31, together with additions...
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