Memorandum Opinion
DAWSON, Judge:
This case is before us on the Court's own motion to dismiss for lack of jurisdiction. The issues for decision with respect thereto are as follows:
1. Whether the Court on its own motion may inquire into its jurisdiction to hear and decide a case after that case has been tried and briefed on the merits by the parties.
2. Whether the period of time given a taxpayer to file a petition with the Court begins to...
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