MEMORANDUM OPINION
VASQUEZ, Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction and to strike as to the taxable years 1996, 1997, and 1999 (motion to dismiss). Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Background
Petitioner timely electronically filed his...
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