MEMORANDUM OPINION
THORNTON, Judge:
This case is before the Court on respondent's motion for summary judgment and to impose a penalty under section 6673.
Background
The record reveals or the parties do not dispute the following:
Petitioner failed to file a Federal income tax return for 2003. By notice of deficiency dated June 7, 2005, respondent determined a deficiency in petitioner's 2003 tax...
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