MEMORANDUM OPINION
PARKER, Judge:
Respondent determined a deficiency in petitioner's Federal income tax in the amount of $13,726 for the taxable year 1992.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year before the Court, and all Rule references are to the Tax Court Rules of Practice and Procedure.
This case is before us on the parties' cross-motions for summary judgment under...
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