Memorandum Opinion
NIMS, Chief Judge:
This case is before the Court on respondent's Motion for Summary Judgment and petitioners' Cross-Motion for Summary Judgment on the Constitutional Tort Issues.
Respondent determined a deficiency in petitioners Federal income tax for the year 1978 in the amount of $54,810. The deficiency resulted from two adjustments to income made by respondent, as follows:
a. Schedule C [deduction]—Gold...
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