Memorandum Opinion
PAJAK, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b) and Rule 180 et seq. (All section numbers refer to the Internal Revenue Code in effect at the time of the issuance of the statutory notice (April 13, 1988). All rule numbers refer to the Tax Court Rules of Practice and Procedure.)
This matter came before this Court on respondent's Motion to Dismiss for Lack of Jurisdiction. Respondent...
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