Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency in petitioners' Federal income tax in the amount of $7,918 for the taxable year 1984. This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. The petition was filed over 2 years after the mailing of the statutory notice of deficiency. Petitioners refute respondent's position by contending that the statutory notice of deficiency...
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