Memorandum Opinion
WELLS, Judge:
This case is before the Court on respondent's motion for summary judgment.
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year 1981 in the amount of $9,223.60 and an addition to tax under section 6653(a)(1)
The issue to be decided is whether respondent is entitled to summary judgment.
On October 18, 1985...
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