Memorandum Opinion
CLAPP, Judge:
Respondent determined deficiencies in petitioner's Federal excise tax for the years 1975, 1977 and 1978 as follows:
Year Deficiency 1975................ $45,839.03 1977................ $66,207.71 1978................ $64,538.17
The matter is before the Court on petitioner's Motion for Summary Judgment pursuant to Tax Court Rule 121.
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