Memorandum Opinion
WELLS, Judge:
The instant case is before the Court on petitioners' motion to compel respondent to produce certain "Appeals Supporting Statements."
Petitioners' motion asserts certain facts which respondent does not dispute. The facts asserted in petitioners' motion are restated in this Memorandum Opinion solely for the purpose of deciding the instant motion. The notices of deficiency in the instant case determine deficiencies in...
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