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MILLER v. COMMISSIONER

Docket No. 11722-79.

73 T.C. 1039 (1980)

WILLIAM FIELD MILLER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 10, 1980.

Attorney(s) appearing for the Case

William R. Nicholas and John H. Hall, for the petitioner.

Marc J. Winter, for the respondent.

OPINION

FEATHERSTON, Judge:

On November 8, 1979, petitioner filed a motion for summary judgment in this case which involves deficiencies in the amounts of $4,473 and $3,599.75 for 1975 and 1976, respectively. In support of the motion, he filed an affidavit together with a memorandum of points and authorities. Respondent has objected to the motion.

The issues for decision are:

(1) Whether petitioner...

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