MEMORANDUM OPINION
WHERRY, Judge:
This case is before the Court on respondent's motion for partial summary judgment pursuant to Rule 121. Respondent determined Federal income tax deficiencies with respect to petitioners' 1993, 1994, and 1995 taxable calendar years of $6,546, $11,577, and $18,226, respectively. Respondent further determined that petitioner Meri R. Kaufman (Ms. Kaufman) was liable for section 6663 fraud penalties of $4,909.50 for 1993, $8...
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