OPINION
HALPERN, Judge:
This matter is before the Court on the parties' motions for summary judgment (respondent's motion and petitioners' motion, respectively). Both petitioners and respondent have moved for summary adjudication with regard to a question of res judicata. The question is whether the rule of res judicata precludes respondent from litigating an additional deficiency in tax (and additions to tax) on account of petitioners' alleged fraud...
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