Memorandum Opinion
NIMS, Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. (All section references are to sections of the Internal Revenue Code in effect for all periods relevant to this proceeding.)
The relevant facts are not in dispute and may be summarized as follows. Petitioner Mary E. Bryant (petitioner) and her deceased husband filed joint income tax returns for the years at issue. Respondent issued...
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