MEMORANDUM OPINION
VASQUEZ, Judge:
This case is before the Court on respondent's motion for summary judgment. At the time he filed the petition, petitioner resided in Las Vegas, Nevada.
Background
Petitioner failed to file a Federal income tax return for 2000. On August 21, 2002, respondent sent petitioner a statutory notice of deficiency for 2000.
On March 10, 2003, respondent assessed a deficiency in tax and additions to...
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