Memorandum Opinion
FAY, Judge:
Respondent determined a deficiency of $6,173.00 and an addition to tax of $308.65 in petitioners' 1977 Federal income tax. The issues are whether (1) wages are income and (2) any part of petitioners' underpayment was due to negligence.
This case is before us on respondent's motion for summary judgment as to the deficiency and the addition to tax.
All the facts are stipulated to or are deemed admitted pursuant...
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