Memorandum Opinion
WILBUR, Judge:
This matter is before the Court on respondent's motion for summary judgment filed on November 2, 1982. The motion was heard at the Indianapolis trial session on January 24, 1983.
In his statutory notice of deficiency dated July 3, 1980 respondent determined the following deficiencies in petitioner's Federal income tax and additions to tax:
Addition to Tax Year Deficiency...
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