Memorandum Opinion
COLVIN, Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction because the petition in this proceeding was not filed within 90 days after the mailing of the notice of deficiency.
All section references are to the Internal Revenue Code in effect for the years in issue.
Background
Petitioners resided in Wilmington, Delaware, when the petition was filed.
On...
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