Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent has filed a motion to dismiss for lack of jurisdiction on the ground that the petition was not timely filed. Petitioners have made an oral motion to dismiss on the ground that the notice of deficiency was not valid because it was not mailed to petitioners' last known address and on the further ground that the notice of deficiency was not mailed within the 3-year statute of limitations...
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