MEMORANDUM OPINION
ARMEN, Special Trial Judge:
This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction, filed July 2, 1999, and supplemented December 6, 1999. As discussed in detail below, we shall grant respondent's motion.
Background
On October 17, 1997, respondent mailed a notice of deficiency to petitioner determining a deficiency and accuracy-related penalty in petitioner's Federal income tax...
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