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BROWN v. COMMISSIONER

Docket No. 12481-81.

78 T.C. 215 (1982)

HENRY M. BROWN AND BARBARA J. BROWN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 8, 1982.

Attorney(s) appearing for the Case

James E. Bell, for the petitioners.

Henry B. Miller and Robyn R. Jones, for the respondent.

OPINION

DAWSON, Judge:

This case is presently before the Court on respondent's motion to dismiss for lack of jurisdiction. The primary issue for decision is whether a notice of deficiency addressed to petitioners at an APO address in New York was addressed to them at an address outside the United States for purposes of section 6213(a).1 The resolution of this issue will determine whether petitioners were entitled to 150...

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