URBAN v. COMMISSIONER

Memorandum Opinion

PARR, Judge:

This case is before the Court on respondent's Motion for Judgment on the Pleadings filed pursuant to Rule 1201 and respondent's Motion for Imposition of Penalty under section 6673.

In the notice of deficiency, respondent determined deficiencies in and additions to petitioner's individual Federal income tax for calendar year ending December 31, 1982 as follows:

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