Memorandum Findings of Fact and Opinion
IRWIN, Judge:
The issue here is respondent's motion to dismiss this case for lack of jurisdiction because of the failure of petitioner to file a petition within the period prescribed by the applicable provision of the Internal Revenue Code of 1954. Petitioner objected to the motion and a hearing on the motion was held at San Francisco, Calif., on June 15, 1973, at which time petitioner offered evidence in support of...
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