United States Tax Court.
MEMORANDUM OPINION
CHIECHI, Judge:
This case is before the Court on respondent's motion to dismiss for failure to state a claim upon which relief can be granted and to impose a penalty under section 6673 (respondent's motion).
Background
The record establishes and/or the parties do not dispute the following.
Petitioner resided in Long Beach, California, at the time he filed the petition in this...
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