MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge:
This case was heard 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, filed pursuant to Rule 53. Respondent contends that dismissal is warranted on the ground that the petition was not filed within the time prescribed by sections 6213(a) and 7502...
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