Memorandum Opinion
SHIELDS, Judge:
This matter is before us at this time on respondent's motion for summary judgment under Rule 121 that there is a deficiency in income tax plus additions to tax due from petitioner for 1983 as follows:
Additions to Tax Under Sections Deficiency 6653(b)(1)1 6653(b)(2) 6661 $7,133 $3,869 * $1,783 ...
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