Memorandum Findings of Fact and Opinion
WHITAKER, Judge:
This matter is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction filed May 20, 1987. Respondent contends that the petition herein was not filed within the period prescribed by section 6213(a)
On May 2, 1984, respondent mailed a statutory notice of deficiency to petitioner by certified mail...
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