Memorandum Findings of Fact and Opinion
NIMS, Judge:
This case is before us on respondent's motion to dismiss for lack of jurisdiction for the reason that the petition herein was not filed within the requisite 90-day period.
Findings of Fact
The exhibits in this case are incorporated herein by reference.
Respondent issued a statutory notice of deficiency to petitioners for the taxable year 1977 on July 19, 1979. The 90-day period...
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