ADAMS v. COMMISSIONER

Memorandum Opinion

FAY, Judge:

This case is before the Court on respondent's motion for summary judgment filed on December 18, 1984, pursuant to Rule 121.1 Respondent's motion was calendared for hearing on February 26, 1985, at the trial session of the Court in Phoenix, Ariz. Respondent seeks summary judgment as to deficiencies in and additions to petitioner's Federal income tax as follows:

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