Memorandum Opinion
VAN FOSSAN, Judge:
This proceeding was heard on the petitioner's motion to dismiss on the ground that the respondent has never made a determination of any deficiency in income tax against the petitioner, as required by law.
[The Facts]
The petitioner predicates his position on two alleged questions of fact:
1. The statutory notice, the 90-day notice of deficiency, was not served on the petitioner pursuant...
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