DeVILLARS v. COMMISSIONER

Memorandum Opinion

NIMS, Judge:

This case is before the Court on respondent's Motion for Summary Judgment filed April 2, 1986, for a decision in the total amount of the deficiencies in income tax and additions to tax determined by respondent in a deficiency notice sent to petitioner on March 6, 1985. Rule 121, Tax Court Rules of Practice and Procedure. Respondent determined the following deficiencies:

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