Memorandum Opinion
CANTREL, Special Trial Judge:
This case is before the Court on respondent's Motion to Impose Sanctions [under Rule 104(c)]
Respondent, in his notice of deficiency issued to petitioner on May 19, 1983, determined deficiencies in petitioner's Federal income tax and additions to the tax for the taxable calendar years 1979 through 1981 in the following...
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