Memorandum Findings of Fact and Opinion
COLVIN, Judge:
This case is before the Court on petitioner's motion to dismiss for lack of jurisdiction and respondent's cross-motion to dismiss for lack of jurisdiction. The sole issue is whether respondent properly mailed the notice of deficiency for 1986 to petitioner's last known address as required by section 6212. We find that respondent did not.
Respondent determined an $11,560 deficiency in petitioner...
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