Memorandum Opinion
HAMBLEN, Judge:
This case is before the Court on respondent's motion for judgment on the pleadings filed on October 19, 1982, pursuant to Rule 120
Joseph O. Kostner resided in Chicago, Illinois, when he filed his petition in this case on March 30, 1982.
Respondent determined deficiencies in and additions to petitioner's Federal income tax as follows:
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