Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner, in his statutory notice of deficiency, determined the following deficiencies in petitioners' Federal income tax:
Taxable Amount of Deficiency Year 1972 ............... $ 971.60 1973 ............... 2,058.42
The case is before us on respondent's motion for partial summary judgment under Rule 121, Tax Court Rules of Practice and Procedure...
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