MEMORANDUM OPINION
WOLFE, Special Trial Judge:
This case is before us on respondent's motion to dismiss for lack of jurisdiction with respect to petitioner Diana C. Wheeler (Mrs. Wheeler), to change the caption, and to strike as to Mrs. Wheeler. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent contends that this...
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