MEMORANDUM OPINION
NAMEROFF, Special Trial Judge:
By separate notices of deficiency dated February 3, 1999, respondent determined deficiencies in petitioner's 1995 and 1996 Federal income tax of $2,376 and $2,763, respectively. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue.
This matter is before the Court on the parties' cross-motions to dismiss for lack of jurisdiction. Petitioner...
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