MEMORANDUM OPINION
CHIECHI, Judge:
This case is before the Court on respondent's motion for judgment on the pleadings (respondent's motion). We shall grant respondent's motion.
Background
The record establishes and/or the parties do not dispute the following.
Petitioner resided in Hudson, New York, at the time he filed the petition in this case.
Respondent issued to petitioner a notice of deficiency (notice) for his...
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