Memorandum Opinion
DRENNEN, Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction because the petition was not timely filed. At the hearing evidence was received in the form of testimony from counsel for petitioner who prepared and mailed the petition, and the parties were given the opportunity to file briefs.
The statutory notice of deficiency was mailed to petitioner on July 25, 1977. The 90-day period...
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