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deficiency, we shall grant R’s motion to dismiss and
strike so much of the petition as seeks review of the
denial of the request for relief made pursuant to sec.
66(c), I.R.C.
Kathryn Bernal, pro se.
David Jojola, for respondent.
OPINION
DAWSON, Judge: This case was assigned to Chief Special
Trial Judge Peter J. Panuthos, pursuant to the provisions of
section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court
agrees with and adopts the opinion of the Chief Special Trial
Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent’s motion to dismiss for lack of
jurisdiction and to strike as to the taxable years 1993, 1994,
1995, and 1996. As explained in detail below, we shall grant
respondent’s motion to dismiss.2
1 Section references are to the Internal Revenue Code, and
Rule references are to the Tax Court Rules of Practice and
Procedure.
2 The petition places in dispute the taxable year 1992 as
well as the taxable years 1993 through 1996. Respondent does not
seek dismissal with respect to 1992. Thus, the order will strike
references to all tax years other than 1992. As the record is
incomplete, we do not address jurisdictional issues with respect
to 1992 in this opinion.
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