MEMORANDUM FINDINGS OF FACT AND OPINION
CHABOT, Judge:
This matter is before us on respondent's motion to dismiss the instant case for lack of jurisdiction because the petition was not filed within the time prescribed by section 6213(a).
Respondent determined a deficiency in Federal individual income tax against petitioners for 1995 in the amount of $2,821.
The primary issue for decision is whether respondent...
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