Memorandum Opinion
WILBUR, Judge:
This case is before the Court on respondent's Motion for Summary Judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure. Respondent determined a deficiency of $6,769.53 in the 1980 Federal income tax of petitioner John B. Perez, and also determined that he was liable for additions to tax under section 6651(a)(1)
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