Memorandum Opinion
NIMS, Chief Judge:
By statutory notice dated January 13, 1989, respondent determined a deficiency in petitioner's 1985 Federal income tax in the amount of $12,174.59.
On May 25, 1989, respondent filed a motion for summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure, which was heard by the Court on July 12, 1989. Petitioner did not appear at the hearing on this motion. However, on July 24, 1989, petitioner...
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