MEMORANDUM OPINION
WOLFE, Special Trial Judge:
This matter is before the Court on petitioners' Motion to Dismiss for Lack of Jurisdiction, respondent's Motion for Summary Judgment, and respondent's Motion to Impose a Penalty under Section 6673. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
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