ROSE v. COMMISSIONER

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 issue for decision is whether the notice of deficiency was mailed to petitioner's last known address.

Respondent determined deficiencies in and additions to petitioner's 1982, 1983, and 1984 Federal income tax as follows:

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