OPINION OF THE COURT
SLOVITER, Circuit Judge.
This is an appeal by the Commissioner of Internal Revenue from a decision of the Tax Court granting the motion of Carl and Diane Kumpf (taxpayers) for judgment by default. We have jurisdiction over the appeal pursuant to section 7482(a) of the Internal Revenue Code of 1954. We vacate the default judgment and remand to the Tax Court.
On March 29, 1978, the Commissioner issued a deficiency notice to the...
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