MEMORANDUM FINDINGS OF FACT AND OPINION
GOEKE, Judge:
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts is incorporated herein by this reference. Petitioners resided in Brooklyn, New York, when their petition was filed.
On January 5, 2004, respondent determined by notice of deficiency a deficiency...
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