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ESPINOZA v. COMMISSIONER

Docket No. 10562-80.

78 T.C. 412 (1982)

FRANCISCO T. ESPINOZA, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 16, 1982.

Attorney(s) appearing for the Case

William E. Frantz and Clarence H. Glover, Jr., for the petitioner.

Lourdes M. DeSantis and Donald W. Williamson, Jr., for the respondent.

OPINION

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioner's Federal income taxes for 1971 through 1974 and additions to tax for each year under section 6653(b) of the Internal Revenue Code of 1954.1 The petitioner has made a timely motion for summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure,2 wherein he seeks to establish that the statute...

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