Memorandum Opinion
COLVIN, Judge:
This matter is before the Court on respondent's Motion for Summary Judgment under Rule 121.
Respondent determined a deficiency in petitioners' income tax for 1980 in the amount of $6,883.22, and an addition to tax pursuant to section 6653(b) in the amount of $3,441.61.
Petitioners resided in New York, New York, at the time they filed their petition in this case.
On June...
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