Memorandum Opinion
WILES, Judge:
This matter is before the Court on respondent's motion for summary judgment, filed on January 7, 1982, pursuant to Rule 121
Raymond Van Lancker and Deanna Van Lancker, resided in Garden Grove, California, on the date that they filed their petition in this case.
Respondent determined a deficiency in petitioners' 1977 Federal income tax in the
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