Memorandum Opinion
PETERSON, Special Trial Judge:
This case is before the Court on petitioner's Motion for Partial Summary Judgment under Rule 121(b), regarding additions to tax determined by respondent under section 6653(b) for petitioner's taxable years ending August 31, 1986, August 31, 1987, and August 31, 1988. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references...
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