Memorandum Opinion
DRENNEN, Judge:
This matter is before the Court on respondent's motion for summary judgment, made orally at trial on June 6, 1984.
By notice of deficiency dated February 24, 1983, respondent determined the following deficiencies in and additions to petitioners' Federal income tax:
Taxable Additions to Tax Year Deficiency Sec. 6651(a)1 Sec. 6653...
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