DISPOSITIVE:

“WHEREFORE, the petition is GRANTED.  The Decision dated January 21, 2019 of the Court of Tax Appeals (CTA) En Banc in CTA EB No. 1656 (CTA Case No. 8899) is hereby REVERSED and SET ASIDE.

The case is REMANDED to the CTA-Second Division for its resolution on the merits, in accordance with the Decision.

So Ordered.”

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