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HOYT v. COMMISSIONER

Docket No. 13648-97.

76 T.C.M. 262 (1998)

T.C. Memo. 1998-293

Walter J. Hoyt IV and Cynthia M. Witt-Hoyt v. Commissioner.

United States Tax Court.

Filed August 10, 1998.

Attorney(s) appearing for the Case

Raymond Jackson and Michael D. Culy, for the petitioners. Alan E. Staines, for the respondent.

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 on the ground that the petition was not filed within the period prescribed by section 6213(a).1

The issue for decision is whether a notice of deficiency was issued and properly mailed to petitioners for the...

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