Memorandum Opinion
STERRETT, Judge:
By notice of deficiency dated April 15, 1981, respondent determined a deficiency of $9,070.56 in petitioner's Federal income tax for the taxable year 1977. This case is before the Court on respondent's Motion for Summary Judgment filed on January 3, 1984, pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
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