MEMORANDUM OPINION
HALPERN, Judge:
This matter is before the Court on two opposing motions for summary judgment, petitioner's motion for summary judgment (petitioner's motion) and respondent's motion for partial summary judgment (respondent's motion). The motions are in opposition on the question of whether the period of limitations on assessment and collection has run. Petitioner asks that we summarily decide that the assessment or collection of any tax...
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