Memorandum Opinion
PAJAK, Special Trial Judge:
This case was assigned pursuant to section 7443A(b) and Rule 180 et seq. (All section numbers refer to the Internal Revenue Code in effect for the taxable year in issue, unless otherwise indicated. All Rule numbers refer to the Tax Court Rules of Practice and Procedure.)
This case is before the Court on respondent's Motion to Dismiss for Failure to State a Claim Upon Which Relief Can be Granted filed...
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