MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge:
The case assigned Docket No. 14781-96 is before the Court on respondent's Motion for Partial Summary Judgment and petitioner's Cross-Motion for Summary Judgment. The issue to be decided is whether the period of limitations expired prior to the issuance of the notice of deficiency.
The case assigned Docket No. 5898-97 is before the Court on petitioner...
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