MEMORANDUM OPINION
DAWSON, Judge:
This case was assigned to Special Trial Judge John J. Pajak pursuant to Rules 180, 181, and 183. All Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PAJAK, Special Trial Judge:
This case is before the Court on respondent's motion to dismiss for...
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