Memorandum Opinion
WRIGHT, Judge:
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. Petitioners opposed the motion by written response and a hearing was held at a trial session of the Court in Los Angeles, California. At the conclusion of the hearing, the motion was taken under advisement.
The issue for our determination is whether the notice of deficiency was mailed to petitioners at their "last known address...
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