Memorandum Opinion
TANSILL, Special Trial Judge:
This case is before the Court on respondent's Motion for Summary Judgment filed on July 31, 1984, pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
Respondent, in his notice of deficiency mailed to petitioner on November 10, 1983, determined a deficiency in tax and additions to tax as follows for the taxable year 1982:
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