Memorandum Opinion
ARMEN, Special Trial Judge.
This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction. The issue for decision is whether Charles J. Oswald, Jr. (petitioner) filed his petition for redetermination within the 90-day period prescribed by sections 6213(a) and 7502.
Background
On March 24, 1994, respondent mailed a notice of deficiency to petitioner. In the...
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