Memorandum Findings of Fact and Opinion
The basis for this proceeding is the respondent's determination of deficiency in income tax in the amount of $38,981.66 for the year 1958. Upon the filing of a petition for redetermination, the respondent moved to dismiss for lack of jurisdiction. The petitioner filed a counter motion in which it contended that the respondent's motion was not timely made, that the respondent had filed no answer to its petition, and as a result...
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