MEMORANDUM OPINION
WELLS, Judge:
This matter is before the Court on respondent's motion for summary judgment, filed pursuant to Rule 121, and motion to impose a penalty under section 6673. All section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Background
At the time of the filing of the petition, petitioner resided in Millis, Massachusetts...
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