Bruce M. Crow - Page 3

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          most favorable to the party opposing summary judgment.  Dahlstrom           
          v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v.                        
          Commissioner, 79 T.C. 340, 344 (1982).                                      
          As explained in more detail below, we agree with respondent                 
          that this case is ripe for summary adjudication.                            
          Background                                                                  
               On November 16, 1994, respondent issued a statutory notice             
          of deficiency to petitioner determining deficiencies in, as well            
          as additions to and a penalty in respect of, his Federal income             
          taxes as follows:                                                           

              Additions to Tax and Penalty                                            
          Sec.       Sec.       Sec.                                                  
          Year    Deficiency   6651(a)(1)   6654(a)    6662(a), (c)                   
          1991    $18,122         ---         ---      $3,624.40                      
          1992     35,893      $8,836.25    $1,538.92     ---                         
          The deficiencies in income taxes are based on respondent's                  
          determination that petitioner failed to report a number of items            
          of income for both 1991 and 1992, including nonemployee                     
          compensation, unearned income, distributions from individual                
          retirement accounts, installment sale income, capital gains,                
          interest, and dividends.  Respondent also determined that,                  
          because petitioner's wife filed a separate return for 1991 in               
          which she reported itemized deductions, petitioner improperly               
          claimed the standard deduction for that year, and petitioner                
          failed to report wage income for 1992.  Respondent's deficiency             





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