Memorandum Opinion
CANTREL, Special Trial Judge:
This case is before the Court on respondent's Motion for Summary Judgment filed on February 2, 1984, pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
Respondent, in his notice of deficiency issued to petitioner on October 16, 1980, determined a deficiency in petitioner's Federal income tax for the taxable calendar year 1978 in the amount of $3,983.93.<...
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