NIMS, Chief Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction as to section 6621(c). (Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1984 and all Rule references are to the Tax Court Rules of Practice and Procedure.) Section 7721(b) of the Omnibus Budget Reconciliation Act of 1989, Pub. L. 101-239, 103...
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