MEMORANDUM OPINION
VASQUEZ, Judge:
This case is before the Court on respondent's motion for summary judgment and to impose a penalty under section 6673.
Background
Petitioner failed to file Federal income tax returns for 1994, 1995, and 1996.
On November 30, 1999, respondent sent petitioner a statutory notice of deficiency for 1994, 1995, and...
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