Memorandum Opinion
DAWSON, Chief Judge:
Respondent determined a deficiency of $5,047.21 in petitioner's Federal income tax for the year 1973 and an addition to tax of $2,523.61 under section 6653(b), Internal Revenue Code of 1954.
By order dated April 20, 1977, the Court granted respondent's motion for summary judgment with respect to the determined deficiency and limited the trial of this case to the issue of petitioner's liability for the addition...
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