Memorandum Opinion
IRWIN, Judge:
This matter comes before us on respondent's motion to dismiss for lack of jurisdiction on the grounds that the petition herein was filed after the 90-day period provided in section 6213.
On November 12, 1976, respondent sent by certified mail a statutory notice of deficiency to petitioner for the taxable year 1973. The notice of deficiency was mailed to petitioner and his wife (who is...
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