Memorandum Opinion
GOLDBERG, Special Trial Judge:
This case was considered pursuant to the provisions of section 7443A(b)(4) of the Internal Revenue Code of 1986.
This case is before the Court on two motions. First, respondent's motion to dismiss for lack of jurisdiction as to petitioner Susan L. Truskowsky, and to change caption; and second, petitioners' motion for leave to amend petition embodying amendment.
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