Memorandum Findings of Fact and Opinion
COHEN, Judge:
Respondent determined a deficiency of $349,472 in petitioner's Federal income tax liability for 1978. Respondent has moved for dismissal for lack of jurisdiction because the petition was not filed within 90 days after the notice of deficiency was sent. Petitioner has moved for dismissal for lack of jurisdiction on the ground that the statutory notice of deficiency was not sent to petitioner's last known...
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