GOFFE, Judge:
Respondent, on October 9, 1974, filed a motion to dismiss this case for lack of jurisdiction. At the hearing on the motion, we directed the parties to file briefs, and briefs were filed on behalf of petitioner Bobbie Pollen and respondent.
FINDINGS OF FACT
The facts are not disputed. On April 13, 1972, the Commissioner made jeopardy assessments against petitioners covering the taxable years 1965 to 1967, inclusive. On May 2,...
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