Memorandum Opinion
CHABOT, Judge:
This case is before the Court on respondent's motion for partial summary on the issue of whether petitioner must include in his gross income for the years 1979, 1980, and 1981, the amounts of $93,002.79, $302,366.66, and $136,303.89, respectively, not previously reported by him.
Respondent determined deficiencies in Federal individual income tax and additions to tax under section 6653...
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