Memorandum Opinion
WHITAKER, Judge.
There is pending before the Court in this case respondent's Motion for Partial Summary Judgment filed May 18, 1989, and petitioner's responses to respondent's Motion filed June 12, 1989, and July 17, 1989. Respondent seeks to establish facts by collateral estoppel.
Respondent's notices of deficiency for the years 1975 through 1979 determine substantial amounts of unreported income in each year aggregating $849...
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