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for Lack of Jurisdiction on the ground that petitioner lacks the
capacity under Rule 60(c) to invoke this Court's jurisdiction.3
To reflect the foregoing,
An order granting
respondent's Motion to Dismiss
for Lack of Jurisdiction will be
entered.
3 We note that petitioner's tax liabilities may still be
litigated on the merits in this Court in the event respondent
later issues notice of transferee liability to the appropriate
persons. Sec. 6901; Great Falls Bonding Agency, Inc. v.
Commissioner, 63 T.C. 304, 307 (1974).
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Last modified: May 25, 2011