MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge:
This case is before the Court on petitioner's Motion to Reconsider Denial of Motion to Dismiss. As explained in detail below, we shall deny petitioner's motion to reconsider.1
Background
Petitioner, an accountant, is the sole shareholder of an S corporation, John J. Petito C.P.A., P.C. (Petito corporation). On December 29, 1999, respondent issued...
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