Memorandum Opinion
FAY, Judge:
The cross motions to dismiss for lack of jurisdiction, which were filed by the parties herein, were assigned to Special Trial Judge D. Irvin Couvillion for hearing, consideration, and ruling thereon, pursuant to section 7456(d) (redesignated as section 7443A(b) by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755) of the Code
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