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PARKER v. COMMISSIONER

Docket Nos. 20653, 20654.

12 T.C. 1079 (1949)

BERT D. PARKER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. VIOLET L. PARKER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 17, 1949.

Attorney(s) appearing for the Case

Neil D. McCarthy, Esq., for the petitioners.

Robert H. Kinderman, Esq., for the respondent.

OPINION.

DISNEY, Judge:

This matter arises on respondent's motions to dismiss for lack of jurisdiction, on the ground that the petitions were filed on the ninety-first day after mailing of the notices of deficiency. The petitioners do not controvert that fact, but oppose the motions on the ground that the notices of deficiency were not sent to the petitioners' last known address. From evidence adduced and stipulations made, we find the facts, which...

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