Memorandum Opinion
GALLOWAY, Special Trial Judge:
This case is before the Court on respondent's Motion For Judgment On The Pleadings, filed pursuant to Rule 120(a) on December 23, 1989, and petitioner's objection filed January 26, 1989. In his motion, respondent also requested an award of damages under section 6673.
In his notice of deficiency dated November 13, 1984...
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