Memorandum Opinion
STERRETT, Judge:
This case is before the Court on respondent's Motion to Impose Sanctions pursuant to Rule 104, Tax Court Rules of Practice and Procedure.
In his statutory notice of deficiency dated November 16, 1981, respondent determined a deficiency in petitioners' Federal income tax for the year ended December 31, 1978 in the amount of $1,746. The...
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