Memorandum Findings of Fact and Opinion
NAMEROFF, Special Trial Judge:
This case is before the Court on the parties' cross motions to dismiss for lack of jurisdiction. Respondent has moved to dismiss this case on the ground that the petition was untimely. Petitioner has moved to dismiss this case on the ground that the notice of deficiency was not sent to her last known address.
In the notice of deficiency, respondent determined a deficiency for...
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