MEMORANDUM OPINION
ARMEN, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction. Respondent seeks dismissal on the ground that the petition was not timely filed within the time prescribed by section 6213(a) or section 7502. Petitioner objects to respondent's motion...
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