Memorandum Opinion
COLVIN, Judge:
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction and petitioner's cross-motion to dismiss for lack of jurisdiction, or in the alternative, for summary judgment. Respondent determined a $1,035,767.74 deficiency in petitioner's income tax for 1982.
The issues for decision are:
1. Whether petitioner lacks capacity under Rule 60(c), and therefore cannot file a petition...
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