Memorandum Opinion
IRWIN, Judge:
Respondent determined a deficiency of $10,762 in petitioners' Federal income tax for 1977. Petitioners were residents of North Hollywood, California, at the time of the filing of the petition in this case.
This matter is before the Court on the pretrial Motion of Respondent for Summary Judgment filed on May 21, 1981, pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
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