Memorandum Opinion
PETERSON, Special Trial Judge:
This case was assigned pursuant to section 7443A(b) and Rules 180, 181, and 182. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
This case is before the Court on respondent's Motion to Dismiss filed on July 10, 1992, pursuant to Rule 40. Respondent has...
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