Memorandum Opinion
COUVILLION, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b) of the Internal Revenue Code of 1986.
This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction. The issue for decision is whether Carl D. Rader was the proper party to file a petition on behalf of an S corporation, Modern Computer Games, Inc. (Games), during the 90...
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