MEMORANDUM OPINION
VASQUEZ, Judge:
This case is before the Court on respondent's motion for summary judgment and motion to impose a penalty under section 6673.
Background
By notice of deficiency, respondent determined a deficiency of $3,300 and additions to tax of $825 and $176.55 pursuant to sections 6651(a)(1) and 6654(a), respectively, in petitioner's 1997 Federal income tax.
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