Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
The issue before us involves the dismissal of the petition herein as to the taxable years 1969 and 1970. The parties are in agreement that the petition should be dismissed with respect to those years but disagree as to the grounds for such dismissal, i.e., because a proper and timely petition was not filed in respect of those years or because the notice of deficiency for those years was not...
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