Memorandum Opinion
WILBUR, Judge:
This matter comes before the Court on respondent's motion to dismiss for lack of jurisdiction. Petitioner objected to the motion and, after an oral hearing, the parties submitted stipulations of fact and written briefs stating their positions.
Respondent's motion and petitioner's objections essentially raise two issues for our determination: (1) whether this Court lacks jurisdiction under section 6871(b)
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