GUILLO v. COMMISSIONER

MEMORANDUM OPINION

SWIFT, Judge:

This case is before the Court under Rule 121(b) on respondent's motion for summary judgment as to petitioner's liabilities for Federal income and self-employment taxes on unreported income and for additions to tax under sections 6651 and 6654.

Respondent determined deficiencies and additions to tax with respect to petitioner's Federal income and self-employment taxes, as follows:

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