MEMORANDUM OPINION
PARR, Judge:
This case is presently before the Court on respondent's motion for partial summary judgment filed December 11, 1995, pursuant to Rule 121.
By statutory notice, dated March 6, 1995, respondent determined a deficiency in petitioner's Federal income tax for tax year 1986 of $13,147 and additions to tax under sections 6651(a)(1) and 6654 in the amounts of $3,287 and $635, respectively.
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