Memorandum Findings of Fact and Opinion
CHABOT, Judge:
This proceeding is before us on respondent's motion to dismiss for lack of jurisdiction because the petition was not filed within the time prescribed by section 6213.
Findings of Fact
When the petition in this case was filed, petitioners Robert M. Krellman (hereinafter sometimes referred to as "Robert") and Florence Krellman (hereinafter sometimes referred...
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