Memorandum Opinion
RUWE, Judge:
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction on the ground that the petition was filed out of time under section 6213.
Background
The relevant facts can be summarized as follows. On October 16, 1990, respondent issued a statutory notice of deficiency. On January 29, 1991, petitioner filed a petition with this Court. On April...
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