Memorandum Opinion
SCOTT, Judge:
On January 21, 1981, petitioner filed a motion for partial judgment on the pleadings in each of the above-entitled cases. The ground for each of petitioner's motions was stated to be that "all of the additional (second-level) excise taxes are unenforceable and, therefore, the Petitioner is entitled to a Partial Judgment on the Pleadings as to all of the additional taxes as well as the penalties thereon * * *."
The...
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