MEMORANDUM OPINION
HAINES, Judge:
This matter is before us on respondent's motion for summary judgment filed pursuant to Rule 121 and to impose a penalty pursuant to section 6673.
Background
At the time this petition was filed, petitioner resided in Warner Robins, Georgia.
On August 22, 2001, petitioner and his wife, Sandra C. Krueger, filed a joint Federal income tax return for 2000 (2000 tax...
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