Memorandum Opinion
CANTREL, Special Trial Judge:
This case is before the Court on respondent's Motion to Impose Sanctions [under Rule 104] and to Impose Damages Pursuant to Section 6673 of the Internal Revenue Code filed on December 13, 1984.
Respondent, in his notice of deficiency issued to petitioners on March 25, 1982, determined a deficiency in petitioners' Federal income tax for the taxable calendar year 1978 in...
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