MEMORANDUM OPINION
CHIECHI, Judge:
This case is before the Court on respondent's motion for summary judgment (respondent's motion). We shall grant respondent's motion.
Background
Petitioners resided in Bowie, Maryland, at the time they filed the petition in this case.
On May 8, 1997, respondent issued to petitioners a notice of deficiency (notice) determining a deficiency in, and an accuracy-related penalty under section...
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