Memorandum Opinion
PETERSON, Special Trial Judge:
This case was assigned pursuant to section 7443A(b) and Rules 180, 181, and 182. Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.
This case is before the Court on petitioner's Motion to Dismiss for Lack of Jurisdiction filed March 6, 1992. Respondent filed a Notice of Objection to petitioner...
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