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
Herbert J. Stoll and Richard L. Barovick (hereinafter referred to as "the administrators") are the administrators of the Estate of Murray Levison, deceased, having been so...
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