MEMORANDUM OPINION
HAINES, Judge.
This case is before the Court on petitioner's motion to vacate order and decision pursuant to Rule 162.
For the reasons stated below, we shall deny petitioner's motion to vacate.
Background
On November 13, 2003, respondent issued a notice of deficiency to petitioner that determined a deficiency in petitioner's 2000 Federal income tax and a penalty under section...
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