TACHA, Circuit Judge.
Appellants William and Wanda Scheidt appeal from an order of the United States Tax Court denying both their motion to dismiss for lack of jurisdiction and their motion for summary judgment. On appeal, appellants contend that the Commissioner's misaddressed notice of deficiency to appellants failed to toll the three-year limitation period before which the Commissioner must assess tax deficiencies. We exercise jurisdiction under 26 U.S.C. §...
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