MEMORANDUM FINDINGS OF FACT AND OPINION
COUVILLION, Special Trial Judge:
These consolidated cases are before the Court on the parties' motions to dismiss for lack of jurisdiction. In docket No. 16948-97, petitioner moves to dismiss on the ground that the notice of deficiency is invalid because it was not mailed to petitioner's last known address. Respondent argues that the notice of deficiency was mailed to petitioner's last known address. In Docket Nos...
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