Memorandum Opinion
WILES, Judge:
This matter is before the Court on respondent's "Motion For Summary Judgment" filed October 16, 1978, pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies of $8,313.52 and $11,936.00 in petitioners' 1974 and 1975 Federal income tax. Petitioners were residents of Portland, Oregon, when they filed their 1974 and 1975 returns...
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