Memorandum Findings of Fact and Opinion
NIMS, Judge:
This case is before us on petitioners' motion to dismiss for lack of jurisdiction. Petitioners assert that the deficiency notice which respondent issued was not valid.
Findings of Fact
At the time the petition in this case was filed, petitioners resided in Dallas, Texas.
Petitioners filed their 1974 Federal income tax return with the District Director, Internal Revenue Service...
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