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To reflect the foregoing,
An order will be entered
granting respondent's Motion to
Dismiss for Lack of Jurisdiction
and denying petitioner's Motion to
Dismiss for Lack of Jurisdiction.
and, if the claim is denied, sue for a refund in the Federal
District Court or the U.S. Court of Federal Claims. See
McCormick v. Commissioner, 55 T.C. 138, 142 (1970).
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Last modified: May 25, 2011