Memorandum Opinion
STERRETT, Judge:
This case is presently before the Court on both respondent's and petitioners' Motions to Dismiss for Lack of Jurisdiction filed pursuant to Rule 53, Tax Court Rules of Practice and Procedure. The sole issue for decision is whether respondent mailed the deficiency notice herein to petitioners at their "last known address" as that phrase is used in section 6212(b)(1), I.R.C. 1954.
Petitioners William G. Foster and...
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