MEMORANDUM OPINION
DAWSON, Judge:
This case was assigned to Special Trial Judge John F. Dean pursuant to the provisions of section 7443A(b)(5), in effect when this case commenced, and Rules 180 and 181 and Interim Rule 183. Unless otherwise indicated, section references are to the Internal Revenue Code as in effect for the tax years for which petitioner seeks abatement of interest. All Rule references are to the Tax Court Rules of Practice and Procedure...
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