MEMORANDUM OPINION
RUWE, Judge.
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent bases his motion on the ground that the petition was not filed by a proper party under Rule 60(c).
Background
On February 5, 2001, respondent mailed a notice of deficiency for the taxable years 1994 and 1995 to "Northstate Tax Consultants Trust". On May 7, 2001, a petition...
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