OPINION
HALPERN, Judge:
Respondent has determined deficiencies in petitioner's income tax for 1983, 1985, and 1986. Petitioner has moved for partial summary judgment. Petitioner's motion is limited to one question, concerning the statute of limitations, for 1 year, 1983. This opinion addresses only petitioner's motion.
A summary judgment is appropriate if the pleadings and other materials show that there is no genuine issue as to any material...
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