Memorandum Opinion
WILES, Judge:
This matter is before the Court on respondent's "Motion to Dismiss for Lack of Jurisdiction" filed February 8, 1977. Respondent contends that the petition herein was not filed within the period prescribed by section 6213(a).
Respondent determined income tax deficiencies for 1973 and on September 15, 1976, mailed to petitioner, as transferee, notices of liability. On Thursday, December...
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