Memorandum Opinion
WELLS, Judge:
The instant case is before the Court on respondent's motion to hold petitioner in default pursuant to Rule 123(a). All Rule references are to the Tax Court Rules of Practice and Procedure, and, unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue.
Respondent determined deficiencies in and additions to petitioner's Federal income taxes as follows...
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