Supplemental Memorandum Opinion
NIMS, Chief Judge:
This matter is before the Court on petitioner's motion to amend the Court's June 4, 1991, order denying petitioner's motion to dismiss for lack of jurisdiction. Petitioner is seeking an interlocutory appeal pursuant to section 7482(a)(2) and Rule 193. (Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the year in issue. All Rule references are to the Tax...
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