Memorandum Opinion
PAJAK, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rule 180 et seq. (Unless otherwise indicated, all section numbers refer to the Internal Revenue Code in effect for the taxable year in issue, and all Rule numbers refer to the Tax Court Rules of Practice and Procedure.)
This case is before the Court on respondent's Motion For Judgment on the Pleadings Under Rule 120 and respondent...
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