MEMORANDUM OPINION
WELLS, Judge:
This case is before the Court on respondent's motion for summary judgment pursuant to Rule 121(a).
Respondent determined a deficiency in petitioners' 1992 Federal income tax in the amount of $21,714.06 and an addition to tax pursuant to section 6651(a)(1) in the amount of $92.61.
In support of respondent's motion for summary judgment, respondent filed an affidavit along with exhibits...
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