BALDWIN v. COMMISSIONER

Memorandum Opinion

STERRETT, Judge:

This case is before the Court on respondent's Motion for Summary Judgment filed on February 1, 1984, pursuant to Rule 121, Tax Court Rules of Practice and Procedure.1

Respondent, in his notice of deficiency dated October 13, 1981, determined the following deficiency in petitioner's 1978 Federal income tax and addition to tax for fraud under section 6653(b), I.R.C. 1954:

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