Memorandum Opinion
STERRETT, Judge:
This case is presently before the Court on respondent's motion to dismiss for lack of jurisdiction filed pursuant to Rules 53 and 60, Tax Court Rules of Practice and Procedure. The sole issue for decision is whether petitioner a corporation, had the capacity to bring a case in this Court at the time it filed its petition on December 22, 1980.
Petitioner, a Florida corporation, was legally dissolved under the laws...
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