SHIELDS, Judge:
This matter is before the Court at this time on a motion by each party for summary judgment under Rule 121.
For 1986 respondent determined a deficiency in petitioners' income tax in the amount of $29,400 and an addition to tax under section 6659 for a valuation overstatement in the amount of $8,820. However, the parties have stipulated that there was no valuation overstatement on petitioners' return for...
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