Memorandum Opinion
SWIFT, Judge:
Respondent determined a deficiency in petitioners' 1981 joint Federal income tax in the amount of $113,392, increased interest under section 6621(c), and a negligence addition to tax under section 6653(a)(1) and (2). The parties have submitted to the Court under Rule 122 the issue of whether respondent's notice of deficiency is valid and whether respondent timely provided an explanation for the disallowance of a loss claimed...
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