Memorandum Opinion
WHITAKER, Judge:
This case is before the Court on respondent's motion for summary judgment, filed November 3, 1982, and petitioners' motion to file reply out of time, filed January 17, 1983. A hearing on these motions was held on January 24, 1983.
Respondent determined separate deficiencies against each petitioner in the following amounts:
Gerald Savole— ...
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