PER CURIAM.
This matter is before the Court upon petitioner's appeal from the Tax Court's judgment granting summary judgment for respondent, affirming the Commissioner's deficiency determination and awarding damages pursuant to 26 U.S.C. § 6673. This case has been referred to a panel of the Court pursuant to Rule 9(a), Rules of the Sixth Circuit. Upon examination of the briefs and record, this panel agrees unanimously that oral argument is not needed. Rule 34...
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