Memorandum Opinion
GUSSIS, Special Trial Judge:
This case is before the Court on respondent's motion to dismiss for failure to state a claim for relief pursuant to Rule 40 and for damages (now designated as a penalty) under section 6673. See sec. 7443(A)(b)(4). All section references are to the Internal Revenue Code as in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Respondent issued statutory...
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