MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 183.
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction, petitioner's motion to dismiss for lack of jurisdiction, and petitioner's motion to restrain collection. Although respondent contends that this case must be dismissed on...
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