Per Curiam.
On September 8, 1993, appellant filed a notice of appeal with the BTA contesting the assessments made against him, and appealing the commissioner's certifcate of final determination dated August 21, 1991. The commissioner filed a motion to dismiss appellant's appeal, contending that the notice of appeal was not filed with the BTA in a timely manner.
The appellant contends that his notice of appeal was filed in a timely manner because it...
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