Memorandum Opinion
HAMBLEN, Judge:
This case is before us on respondent's motion for summary judgment pursuant to Rule 121.
Respondent determined a deficiency in the amount of $16,217.50 in petitioners' 1977 individual Federal income tax. He further determined additions to tax in the amounts of $4,184.94 and $923.43 pursuant to sections 6651(a) and 6653(a), respectively.
Respondent's determination was based primarily...
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