Memorandum Opinion
WILES, Judge:
This matter is before the Court on respondent's "Motion to Dismiss for Lack of Jurisdiction" filed July 31, 1981, pursuant to Rule 53, Tax Court Rules of Practice and Procedure. A hearing on this motion was held on October 19, 1981, in San Antonio, Texas. Respondent, who determined a $3,236 deficiency in petitioners' 1978 Federal income tax, contends that the petition herein was not filed within the period prescribed in section...
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