OPINION
TANNENWALD, Judge:
This case is before us on respondent's motion to dismiss for lack of jurisdiction insofar as the petition herein seeks to put partnership items in issue for 1982.
All of the relevant facts and documents have been stipulated and are so found.
Petitioner resided in California when he filed the petition in this case. He timely filed a Federal income tax return for the 1982 taxable year with the Internal Revenue...
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