Memorandum Opinion
STERRETT, Judge:
This matter is presently before the Court on petitioners' Motion for Summary Judgment filed April 15, 1983 pursuant to Rule 121, Tax Court Rules of Practice and Procedure. The issue for decision is whether a valid notice of deficiency was issued to petitioners within the 3-year statute of limitations period provided in section 6501(a), I.R.C. 1954. Specifically, we first must decide whether the notice of deficiency dated...
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