Memorandum Findings of Fact and Opinion
PARKER, Judge.
This matter is before the Court on petitioner's motion to restrain assessment and collection and respondent's motion to dismiss for lack of jurisdiction on the ground that the petition was not filed within the time prescribed by law. Petitioner concedes that, if respondent's motion is granted, then his motion becomes moot.
Respondent determined a deficiency in petitioner's Federal income tax...
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