MEMORANDUM OPINION
Thornton, Judge.
This case is before the Court on respondent's motion for summary judgment.
Background
The record reveals or the parties do not dispute the following:
Petitioner failed to file Federal income tax returns for 1985, 1986, 1987, 1988, 1989, 1990, 1991, and 1992. By three separate notices of deficiency dated December 8, 1995,...
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