Memorandum Opinion
DINAN, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986.
On December 8, 1988, respondent filed a Motion To Dismiss For Failure To State A Claim Upon Which Relief Can Be Granted, pursuant to Rule 40.
On July 28, 1988, respondent mailed to petitioner a statutory notice of deficiency in which respondent determined the...
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