Memorandum Opinion
SCOTT, Judge:
This case was assigned to Special Trial Judge Pajak pursuant to section 7443A(b) of the Code and Rule 180 et seq. The Court agrees with and adopts his opinion which is set forth below.
Opinion of the Special Trial Judge
PAJAK, Special Trial Judge:
This case is before the Court on respondent's motion for summary judgment under Rule 121.
Respondent determined a deficiency in petitioner's Federal...
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