Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
This case is before the Court on cross-motions to dismiss for lack of jurisdiction. Respondent moves that the case be dismissed on the ground that the petition was not timely filed. Petitioner asks that the case be dismissed on the ground that the notices of deficiency were invalid.
The case involves 4 years, 1976, 1977, 1978, and 1979. Two notices of deficiency, one for 1976 and 1977 and...
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