Memorandum Opinion
DAWSON, Judge:
This matter is before the Court on respondent's motion for summary judgment filed on January 25, 1982. The motion was heard at the Denver Trial Session on March 22, 1982.
In his statutory notice of deficiency dated February 5, 1981, respondent determined the following deficiency in petitioner's Federal income tax and additions to tax:
Additions to Tax Year ...
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