MEMORANDUM OPINION
SWIFT, Judge:
This matter is before us on respondent's motion under Rule 121 for summary judgment.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issue for decision is whether respondent abused his discretion in relying upon transcripts of account to verify assessment of...
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