Memorandum Opinion
SCOTT, Judge:
This case came on for hearing in San Diego, California, on respondent's motion to dismiss for lack of jurisdiction because the petition was not filed within 90 days of the date of the mailing of the notice of deficiency.
The record shows that a notice of deficiency was mailed by certified mail to petitioners at their address in National City, California, on August 18, 1980. At the time the notice of deficiency was...
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