Memorandum Opinion
NIMS, Judge:
On January 27, 1986, respondent timely filed a motion to dismiss this case insofar as it relates to the taxable year 1980 for lack of jurisdiction and to strike all references to the taxable year 1980 from the amended petition. The motion was based on respondent's contention that the petition filed by petitioner did not raise the taxable year 1980 and that no other petition was filed within the statutory 90-day period with...
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