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TYLER v. COMMISSIONER

Docket No. 23094-83.

50 T.C.M. 1197 (1985)

T.C. Memo. 1985-510

James and Mabel Tyler v. Commissioner.

United States Tax Court.

Filed September 26, 1985.

Attorney(s) appearing for the Case

John J. O'Toole, David L. Kay and G. Michael Saran, 101 Eisenhower Pkwy, Roseland, N. J., for the petitioners. Joy M. Miyasaki, for the respondent.

Memorandum Findings of Fact and Opinion

PARKER, Judge:

Respondent determined a deficiency in petitioners' 1978 Federal income tax in the amount of $37,205. The case is before the Court on respondent's motion to dismiss for lack of jurisdiction. The issue for decision is whether respondent's statutory notice of deficiency was mailed to petitioners' "last known address," within the meaing of section 6212(b)(1).1

Findings...

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