MEMORANDUM OPINION
WELLS, 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. All section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Background
At the time of the filing of the petition, petitioner resided in Bloomingdale, Georgia.
On March 30, 2003...
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