Memorandum Opinion
NIMS, Judge:
This case is before us on respondent's motion to dismiss for lack of jurisdiction.
On April 1, 1981, respondent mailed to petitioner by certified mail a statutory notice of deficiency determining a deficiency in petitioner's estate tax of $227,895.58.
On June 30, 1981, the 90th day after the notice of deficiency was mailed (and not a Saturday, Sunday or legal holiday in the District of Columbia), petitioner...
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