MEMORANDUM OPINION
CHIECHI, Judge:
This case is before the Court on respondent's motion for summary judgment (respondent's motion). We shall grant respondent's motion.
Background
The record establishes and/or the parties do not dispute the following.
At the time the petition was filed, petitioner Mohammed Ali Gazi (Mr. Gazi) resided in Pikesville, Maryland.
On January 30, 1998, respondent issued a notice of deficiency...
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