MEMORANDUM OPINION
ARMEN, Special Trial Judge:
This matter is before the Court on respondent's Motion To Dismiss For Failure To State A Claim Upon Which Relief Can Be Granted. As explained in detail below, we shall grant respondent's motion.
Background
On January 6, 1999, respondent sent petitioner a notice of deficiency. In the notice, respondent determined a deficiency in petitioner's Federal income tax for the taxable 1996 year...
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