Memorandum Opinion
SHIELDS, Judge:
This case is before the Court on the respondent's motion to dismiss for lack of jurisdiction. The only question to be decided is whether or not the petition was timely filed under section 6213.
For the year 1978, Theodore R. Giergielewicz (hereinafter referred to as the petitioner) and Linda J. Giergielewicz, filed a joint income tax return. The petitioner resided at 293 English Court...
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