JEROME v. COMMISSIONER

Memorandum Findings of Fact and Opinion

LARO, Judge:

This case is before the Court on respondent's motion to hold petitioner in default pursuant to Rule 123(a).1 For purposes of this opinion, we treat respondent's motion as a motion for summary judgment under Rule 121.

Respondent determined deficiencies in, and additions to, petitioner's Federal income tax as follows:

                                  Additions...

                    
                    
                    

                        

                            

                                

                            
                            

                                

                                    

                                        

                                        

                                        

                                    
                                
                                

                                    
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