Memorandum Opinion
WHITAKER, Judge:
This case is before the Court on Respondent's Motion for Summary Judgment, filed October 6, 1989. The case is presently calendared for trial at the Court's trial session commencing on January 22, 1990, in Baltimore, Maryland.
In his statutory notice of deficiency dated October 11, 1988, respondent determined the following deficiencies in and additions to petitioner's Federal income tax.
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