Memorandum Opinion
WILES, Judge:
This matter is before the Court on respondent's motion for judgment on the pleadings, filed on October 27, 1981, pursuant to Rule 120
James J. Garvey (hereinafter petitioner) and Doris E. Garvey, husband and wife, resided in Dunwoody, Georgia, on the date they filed their petition in this case. They filed their 1974 joint Federal income tax return with the...
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