Memorandum Finding of Facts and Opinion
DRENNEN, Judge:
Respondent determined a deficiency in petitioner's income tax for the year 1971 in the amount of $402.80. Petitioner mailed a petition to this Court which was received and filed on October 29, 1974. On December 10, 1974, respondent filed a motion to dismiss the case for lack of jurisdiction on the ground that the petition was not timely filed. A hearing on the motion was held in New York City on February...
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