MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge:
This matter is before the Court on respondent's Motion to Dismiss for Failure to State a Claim Upon Which Relief Can be Granted. As explained in detail below, we shall grant respondent's motion.
Background
On August 19, 1992, petitioner filed a Federal income tax return for 1991 reporting a tax liability of $6,795. Respondent subsequently entered assessments against petitioner...
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