MEMORANDUM OPINION
ARMEN, Special Trial Judge:
This matter is before the Court on respondent's Motion To Dismiss For Failure To State A Claim And To Impose A Penalty Under I.R.C. §6673.
Background
A. Petitioner's Form 1040 for 1997
On or about April 15, 1998, petitioner submitted to respondent a Form 1040, U.S. Individual...
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