MEMORANDUM OPINION
ARMEN, Special Trial Judge.
This case is before the Court on respondent's Motion To Dismiss The Tax Years 1995 And 1996 For Failure To State A Claim Upon Which Relief Can Be Granted, filed pursuant to Rule 40.
Background
On October 29, 1998, respondent issued a notice of deficiency to petitioner determining a deficiency of $2,891 in his Federal income tax for 1997. The notice of deficiency...
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