Memorandum Opinion
NIMS, Judge:
This case is before the Court on petitioners' motions to compel discovery compliance and to shift the burden of proof, which is treated as a motion to shift the burden of going forward with the evidence, and to dismiss.
Cleveland Ramsey (petitioner), who worked as a self-employed sales contractor during 1979, and Gladys Ramsey, his wife, timely filed a joint Federal income tax return for 1979 on which they reported...
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