Memorandum Opinion
CANTREL, Special Trial Judge:
This case is before the Court on respondent's Motion for Summary Judgment filed on July 23, 1984, pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
Respondent, in his notice of deficiency issued to petitioners on June 29, 1983, determined a deficiency in petitioners' Federal income tax for the taxable calendar year 1980 in the amount of $3,534.00 and an...
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