ORDER
DUPREE, District Judge.
On March 30, 1993, James T. Smith, acting as tax matters person for Smith S, Inc. ("plaintiff"), filed a petition for readjustment pursuant to 26 U.S.C. §§ 6226(a)(2) and 6244 (1989), of a Final S Corporation Administration Adjustment ("FSCAA") issued by the Commissioner of the Internal Revenue Service ("IRS"). The court has jurisdiction to hear the case pursuant to 28 U.S.C. § 1346(e) (Supp.1993). The action...
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