Memorandum Opinion
SCOTT, Judge:
When this case was called for trial on March 8, 1982, pursuant to notice previously given, respondent filed a motion to dismiss for lack of jurisdiction on the ground that the petition was not filed within 90 days after the mailing to petitioners by certified mail at their last known address of a notice of deficiency. Petitioners orally moved that this case be dismissed on the ground that the notice of deficiency was not...
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