MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent bases his motion upon the ground that the petition was not filed within the period prescribed by section 6213(a).
The issues for decision are: (1) Whether a notice of deficiency was issued and properly mailed to petitioners for the year 1987; and, if so (2) whether...
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