Memorandum Opinion
RUWE, Judge:
This case is presently before the Court on respondent's motion to dismiss for lack of jurisdiction and petitioner's cross motion to dismiss for lack of jurisdiction. The sole issue for decision is whether the notice of deficiency was mailed to petitioner's "last known address" within the meaning of section 6212(b).
Respondent determined a deficiency of $17,983.10 in petitioner's Federal...
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