OPINION
WILES, Judge:
On October 3, 1977, respondent filed a motion for summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
Respondent determined the following deficiencies in petitioners' income taxes:
Docket Nos. Year Deficiency 10291-75 ----------------- 1970 $13,695.71 1971 3,311.75 ...
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