United States Tax Court.
MEMORANDUM OPINION
VASQUEZ, Judge.
This case is before the Court on respondent's motion for summary judgment pursuant to Rule 121.
Background
At the time he filed the petition, petitioner resided in Beverly Hills, California.
On January 11, 1995, respondent mailed petitioner a notice of deficiency determining deficiencies and additions to tax for 1989 and 1990. On September 22, 2003, respondent...
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