OPINION
SCOTT, Judge:
On February 22, 1980, respondent filed in this case a motion to dismiss for lack of jurisdiction on the ground that the petition was not filed within the time prescribed by statute. Petitioners filed objections thereto, and a hearing was held in Los Angeles, Calif., on May 14, 1980.
The facts are not in dispute. On September 18, 1979, respondent mailed to petitioners, by certified mail, a statutory notice of deficiency...
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