OPINION
DAWSON, Judge:
On March 19, 1980, petitioner filed a "Motion For An Order Requiring Respondent To Answer Petitioner's Interrogatories 1-248" under Rule 71, Tax Court Rules of Practice and Procedure. On April 28, 1980, respondent filed a "Motion For Protective Order" under Rule 103, Tax Court Rules of Practice and Procedure. A hearing was held on April 28, 1980, at Philadelphia where both parties made oral arguments, and the petitioner submitted...
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