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SMITH v. COMMISSIONER

Docket No. 7764-77.

38 T.C.M. 51 (1979)

T.C. Memo. 1979-16

Ray Gene Smith and Karen Smith v. Commissioner.

United States Tax Court.

Filed January 9, 1979.

Attorney(s) appearing for the Case

Robert D. Grossman, Jr., 2020 K St., N.W., Washington, D.C., for the petitioners. Steven Mopsick, for the respondent.

Memorandum Opinion

DRENNEN, Judge:

Petitioners have moved for a dismissal for lack of jurisdiction with regard to the taxable years 1972 and 1973 on the ground that they did not receive a valid notice of deficiency with regard to those taxable years. The issues presented by this motion are (1) whether a notice of deficiency which states on the front page printed form that deficiencies are determined for the years 1971, 1974, and 1975, but has attached to...

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