Memorandum Findings of Fact and Opinion
SWIFT, Judge:
This matter is before the Court on the parties' cross-motions to dismiss for lack of jurisdiction. Respondent's motion is based on the fact that the petition herein was filed beyond the 90-day period in section 6213.
Petitioner's motion is based on the argument that respondent failed to mail the notice of deficiency herein to petitioner's last known address, as required...
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