Memorandum Opinion
WILES, Judge:
This case is before the Court on respondent's motion for judgment on the pleadings, filed on March 28, 1983, and heard on June 20, 1983.
Petitioners Buddy L. Snead and Ligaya Snead, husband and wife, resided in Elmdale, Kansas, on the date they filed their petition in this case. They filed joint Federal income tax returns with the Internal Revenue Service for 1978 and 1979.
In the statutory notice, respondent...
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