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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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