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STOTTER v. COMMISSIONER

Docket No. 6833-77.

69 T.C. 896 (1978)

ARTHUR STOTTER AND DORIS STOTTER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 7, 1978.

Attorney(s) appearing for the Case

Jon M. Adelstein and J. Richard Greenstein, for the petitioners.

Edward I. Foster, for the respondent.

OPINION

SIMPSON, Judge:

On August 31, 1977, the Commissioner filed a motion to dismiss this case on the ground that the Court lacks jurisdiction. The only issue for decision is whether the petition in this case was timely filed.

On March 29, 1977, the Commissioner sent, by certified mail, a deficiency notice to the petitioners at their last known address, in which he determined deficiencies in their Federal income

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