Memorandum Findings of Fact and Opinion
NIMS, Judge:
This case is before the Court on respondent's motion for summary judgment filed December 9, 1986, for a decision in the total amount of the deficiencies in income tax and additions to tax determined by respondent in a deficiency notice sent to petitioner on November 6, 1984. Respondent alleges that there are no genuine issues of fact. Petitioner has not raised any issue of fact, and we find that no issue...
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