Memorandum Opinion
NIMS, Judge:
This case is before us on petitioner's motion for summary judgment made pursuant to Rule 121. The basis for the motion is that the statute of limitations bars the collection of certain additions to tax under section 6653(b).
The following is a summary of the undisputed facts.
Petitioner Timothy J. Murphy resided at Milton, Massachusetts, at the time he filed the petition.
Petitioner and his now deceased...
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