OPINION
WILES, Judge:
This matter is before the Court on respondent's "Motion to Dismiss for Lack of Jurisdiction" filed December 22, 1977. Respondent contends that the petition herein was not filed within the period prescribed by section 6213(a).
Respondent determined income tax deficiencies of $3,648 and $1,152 for 1972 and 1973, respectively, and additions to tax under section 6651(a) in the amounts of $36...
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