Memorandum Opinion
GERBER, Judge:
This case is before the Court on respondent's motion for summary judgment and petitioner's cross-motion for summary judgment, each filed pursuant to Rule 121.
Respondent determined a deficiency in petitioner's 1980 Federal income tax in the amount of $4,795 by a notice of deficiency dated February 15, 1985.
The issue for our consideration is whether...
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