Memorandum Opinion
ARMEN, Special Trial Judge:
This case is before the Court on (1) Respondent's Motion to Dismiss for Lack of Jurisdiction as to Determination of Dischargeability of Taxes and Additions to Tax for the Taxable Year 1982 (respondent's jurisdictional motion) and (2) petitioners' Motion for Summary Judgment, filed pursuant to Rule 121.
Respondent determined the following deficiency in, and additions to,...
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