Memorandum Opinion
KORNER, Judge:
This matter is before the Court on cross-motions for summary judgment by petitioner and for partial summary judgment by respondent. The following facts, all stipulated by the parties, are present.
By statutory notice dated July 9, 1992, respondent determined a deficiency of income tax against petitioner and his ex-wife for $28,361, together with increased interest under section 6621(c) for the year 1977.
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