Memorandum Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes for 1971 and 1972 in the respective amounts of $4,930 and $19,291. In addition, he determined that petitioner Roger V. Palmateer (Roger) is liable for additions to tax under section 6653(b)
Respondent filed a motion for partial summary judgment...
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