OPINION
GOFFE, Judge:
On April 17, 1975, petitioner filed a "Motion for Leave to Commence Discovery Prior to Formal Joinder of Issue" pursuant to Rule 70(a)(2), Tax Court Rules of Practice and Procedure. Respondent filed his objections on April 28, 1975, and a hearing on the motion was held on that date.
The Commissioner determined in his statutory notice of deficiency mailed to petitioner on October 4, 1974, that petitioner underpaid his...
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