Memorandum Opinion
FEATHERSTON, Judge:
Respondent has filed a motion pursuant to Rule 40 of this Court's Rules of Practice and Procedure to dismiss the petition for failure to state a claim on which relief can be granted in this case involving determined deficiencies in income tax for 1975 and 1976 in the amounts of $2,717.43 and $3,845.30, respectively.
The petition does not contain any assignments...
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