Memorandum Findings of Fact and Opinion
WILLIAMS, Judge:
This case is before the Court on petitioner's Motion to Dismiss for Lack of Jurisdiction.
The Commissioner determined a deficiency in Federal income tax for the decedent's taxable year ended December 31, 1982 in the amount of $12,449.36. The issue this Court must decide is whether the partnership audit and litigation provisions, sections 6221 to 6233,
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