MEMORANDUM OPINION
DINAN, Special Trial Judge:
This case was called from the calendar of the trial session at San Francisco, California, on January 22, 2001, for hearing on respondent's Motion to Dismiss for Failure to State a Claim Upon Which Relief Can Be Granted, filed November 6, 2000, and petitioner's Notice of Objection, filed December 4, 2000. The parties appeared and were heard.
Background
In a statutory notice of deficiency...
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