CROCKER v. COMMISSIONER

Memorandum Opinion

DAWSON, Judge:

This case is before us on respondent's motion for summary judgment. A hearing thereon was held at Helena, Montana, on October 4, 1982. Petitioner and the attorney who then represented him were present and opposed respondent's motion.

On January 9, 1980, respondent mailed a notice of deficiency to petitioner in which he determined Federal income tax deficiencies and additions to tax as follows:

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