Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
This matter is before the Court at this time on a motion by each party for summary judgment. The parties have also submitted a stipulation of facts and each party has submitted a brief in support of his respective position.
In his motion respondent seeks summary judgment (1) that a notice of deficiency mailed by respondent to petitioner on April 14, 1988, constitutes a valid notice of deficiency...
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