MEMORANDUM OPINION
SWIFT, Judge.
This matter is before us on respondent's motions to dismiss for lack of jurisdiction under Rule 53 and for summary judgment under Rule 121.
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.
Respondent's motion to dismiss is based on the contention that petitioner's request for a section...
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