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SYLVAN v. COMMISSIONER

Docket No. 3542-74.

65 T.C. 548 (1975)

FRED SYLVAN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 16, 1975.

Attorney(s) appearing for the Case

Ray K. Babb, Jr., for the petitioner.

Thomas J. Miller, for the respondent.

OPINION

WILBUR, Judge:

This matter is before us upon respondent's motion to dismiss for lack of jurisdiction. Respondent determined a deficiency in income tax due from the petitioner for the taxable year 1971 in the amount of $22,755.10 and, under section 6653(a),1 an addition to the tax in the amount of $1,137.75. Respondent mailed a statutory notice of deficiency to petitioner by certified mail on February 20, 1974....

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