OPINION
WILBUR, Judge:
This matter comes before the Court on respondent's motion to dismiss this case for lack of jurisdiction. The issue presented by respondent's motion is whether the petitioner herein had 150 days rather than 90 days within which to file his petition with this Court under section 6213(a).
All the facts, for purposes of this motion, have been stipulated. The stipulation of facts is incorporated...
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