Memorandum Opinion
WILLIAMS, Judge:
The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable year 1976 in the amount of $3,682.00. The sole issue this Court must decide is whether respondent issued the statutory notice of deficiency to petitioners after the applicable statute of limitations had expired.
The facts of this case have been fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure...
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