OPINION.
KERN, Judge:
This proceeding came on for hearing on July 16, 1952, on a "Motion To Dismiss" for lack of jurisdiction, filed by respondent on June 16, 1952. The proceeding involves denial by respondent of special relief under section 722, Internal Revenue Code, for the years 1941, 1942, 1943, 1944, and 1945. Respondent's position is that petitioner is not "the taxpayer" within the meaning of section 732, I. R. C. The motion was taken under...
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