MEMORANDUM OPINION
ARMEN, Special Trial Judge:
This matter is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction and to Strike Partnership Items (respondent's Motion to Dismiss). The issues to be decided are: (1) Whether the affected items notice of deficiency issued to petitioner is valid; and, if so, (2) whether this Court has jurisdiction in an affected items proceeding to determine whether petitioner is entitled to innocent spouse...
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