Memorandum Findings of Fact and Opinion
STERRETT, Judge:
Respondent, on May 5, 1978, issued a statutory notice in which he determined a deficiency in petitioners' income tax for their taxable year ended December 31, 1976 in the amount of $410 and an addition to tax under section 6653(a), I.R.C. 1954, in the amount of $20.50. On January 3, 1979 Special Trial Judge James M. Gussis granted respondent's motion for partial summary judgment with respect to the...
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