OPINION
SIMPSON, Judge:
On October 16, 1972, the respondent filed a motion to dismiss this case for lack of jurisdiction. Hearings were held on such motion, and the parties have submitted memorandums of law in support of their positions.
The petition in this case was received by the Tax Court on August 14, 1972. It was contained in an envelope bearing a postmark date of August 10, 1972.
Section 6213(a) of the Internal Revenue Code...
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