PER CURIAM:
Robert Mays appeals from the district court's judgment granting the United States summary judgment on his claim for a refund of federal income taxes. The question we must decide is whether Mays failed to present substantial evidence indicating that the tax deficiencies the Commissioner determined against him with respect to his returns for the years 1975, 1976, and 1977 were incorrect.
The Commissioner assessed an additional tax against Mays for...
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