OPINION
DRENNEN, Judge:
This case is presently before the Court on petitioner's motion for judgment on the pleadings on the grounds that respondent's answer shows that petitioner is entitled to judgment as a matter of law. Rule 120, Tax Court Rules of Practice and Procedure.
For each of the years 1973, 1974, and 1975, respondent determined a section 4941(a)(1), I.R.C. 1954,
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