Memorandum Opinion
CLAPP, Judge:
This matter is before us on respondent's motion to dismiss for lack of jurisdiction on the grounds that the petition in this case was not filed within the time prescribed by section 6213(a) or 7502. The issue for decision is whether petitioners were entitled to file their petition within 150 days after the notice of deficiency was mailed. We hold that they were not.
All section references are to the Internal Revenue...
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