SCHOTT v. COMMISSIONER

Memorandum Opinion

SWIFT, Judge:

This matter is before us on cross-motions for summary judgment under Rule 121.1

In notices of deficiency and in an amended answer, respondent determined deficiencies in petitioner's 1983, 1984, and 1985 Federal income tax liabilities and additions to tax as follows:

                                                      Additions to Tax, Secs.
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