Memorandum Opinion
GUSSIS, Special Trial Judge:
This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction filed June 26, 1989. See section 7443A(b) of the Internal Revenue Code. All section references are to the Internal Revenue Code as in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Petitioner was a resident of Tempe, Arizona at the time the petition herein...
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