Memorandum Opinion
PANUTHOS, Chief Special Trial Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent seeks dismissal on the ground that the petition was not timely filed as required by section 6213(a).
Respondent issued two statutory notices of deficiency, both dated September 11, 1991. One notice of deficiency determined a deficiency in petitioner's 1987 Federal...
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