MEMORANDUM OPINION
JACOBS, Judge:
This case is presently before the Court on respondent's Motion For Judgment On The Pleadings pursuant to Rule 120.
Respondent determined a $10,995 deficiency in petitioner's Federal income tax for 1994, and a $2,199 accuracy-related penalty pursuant to section 6662.
Unless indicated otherwise, all section references are to the Internal Revenue Code for the year in issue, and all Rule references are to the...
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