OPINION Parker, Judge: Respondent determined deficiencies in petitioners’ 1975 Federal income taxes in the amounts of $3,007.36 in docket No. 4722-79 and $12,260.39 in docket No. 7554-79. Petitioner Patience C. Jacklin (formerly Patience C. Rivkin) (Patience or the wife) filed a motion for summary judgment in her favor in docket No. 4722-79, under Rule 121, Tax…
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