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ANTHONY v. COMMISSIONER

Docket No. 9470-97.

75 T.C.M. 2348 (1998)

T.C. Memo. 1998-187

Anthony and Gloria Donnora v. Commissioner.

United States Tax Court.

Filed May 21, 1998.

Attorney(s) appearing for the Case

Moshe Schuldinger, for the petitioners. Alan R. Peregoy, for the respondent.

MEMORANDUM OPINION

CHABOT, Judge:

The instant case is before us on petitioners' motion under Rule 411 for leave to file an amended reply and on respondent's motion under Rule 121 for summary judgment.

Background — Procedure

1. Notice of Deficiency; Petition

Respondent determined deficiencies in Federal individual income tax and additions to tax under sections 6653(b)(1)

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