Memorandum Opinion
DAWSON, Judge:
This matter is before the Court on the petitioner's motion for summary judgment. Respondent filed an objection to the motion and a memorandum of points and authorities. Petitioner also filed points and authorities in support of his motion. A hearing on the motion was held on June 11, 1979, at Los Angeles, California.
The pertinent facts may be summarized as follows: Respondent determined a deficiency of $6,963.34...
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