Memorandum Opinion
SCOTT, Judge:
This case is before us on respondent's Motion for Summary Judgment which was filed in Milwaukee, Wisconsin, on March 29, 1978, when the case was called for trial. There is no dispute between the parties as to any material issue or fact.
Respondent determined a deficiency in petitioner's income tax for the calendar year 1974 in the amount of $1,722.05 and additions to tax under sections 6651(a)(1), 6653(a) and 6654...
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