Memorandum Opinion
HALL, Judge:
This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction and on petitioners' Motion for Default of Respondent. The parties agree that if we grant respondent's motion, petitioners' motion becomes moot. Accordingly, we will first address respondent's motion, namely whether petitioners timely filed their petition.
In an undated statutory notice, respondent determined a $2,043 deficiency...
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