OPINION
DRENNEN, Judge:
This matter is before the Court on petitioners' motion to dismiss for lack of jurisdiction. Respondent objected to the motion and, after a hearing, the parties submitted stipulations of fact and briefs stating their positions.
Petitioners' motion and respondent's objection raise two issues: (1) Whether this Court lacks jurisdiction under section 6871(b), I.R.C. 1954,
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