Memorandum Opinion
PAJAK, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182. All section numbers refer to the Internal Revenue Code for the taxable year in issue. All Rule numbers refer to the Tax Court Rules of Practice and Procedure.
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. Petitioners filed an objection. Respondent filed a reply...
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