ORDER
Petitioner appeals from a decision of the Tax Court which determined a deficiency in his federal income tax for 1977. The respondent cross-appeals from the determination which was termed a "net deficiency" rather than the statutory deficiency as defined in 26 U.S.C. § 6211(a). This appeal has been referred to a panel of the court pursuant to Rule 9(a), Rules of the Sixth Circuit. After examination of the briefs, record and appendix, this panel agrees...
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