Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for the calendar years 1974 and 1975 of $324.21 and $1,044.65, respectively, and additions to tax under section 6653(a), I.R.C. 1954,
The issues for decision are (1) whether respondent's motion for partial summary judgment with respect to various issues...
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