MEMORANDUM OPINION
VASQUEZ, Judge:
This case is before the Court on respondent's motion for summary judgment and to impose a penalty under section 6673.
Respondent determined a deficiency of $4,387 in petitioner's 2002 Federal income tax, a section 6654 addition to tax of $146.61, and a section 6651(a)(1) addition to tax of $1,096.75. The issues for decision are: (1) Whether petitioner is liable for the deficiency determined...
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