MEMORANDUM OPINION
NIMS, Judge:
This matter is before the Court on respondent's motion for summary judgment (respondent's motion) pursuant to Rule 121. Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. In their amended petition, petitioners seek the Court's "Review of [respondent's] Failure to Abate...
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