Memorandum Opinion
GALLOWAY, Special Trial Judge:
This case was assigned pursuant to section 7443A(b) and Rule 180 et seq. (All section references are to the Internal Revenue Code as amended and in effect for the taxable years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.) Before the Court for disposition are respondent's written Motion To Dismiss For Failure To State A Claim Upon Which Relief Can Be Granted, filed pursuant...
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