OPINION Tannenwald, Judge: Respondent determined deficiencies in petitioner’s income tax in the amounts of $25,247.68 for the taxable year ended December 31, 1971, and $19,212 for the taxable year ended December 31,1972. The case is before us on petitioner’s motion for summary judgment but, as will subsequently appear, its posture is such that the Court may be in a position t…
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