MEMORANDUM OPINION
NIMS, Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent contends that this Court lacks jurisdiction (1) for the years 1996, 1997, 1998, 1999, and 2001 because no notices of determination were issued for those years; and (2) for the year 2000 because the petition was not timely filed with this Court for reasons hereinafter explained. Unless otherwise indicated, all section references...
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