Memorandum Findings of Fact and Opinion
TANNENWALD, Chief Judge:
This case is before us on each party's Motion to Dismiss for Lack of Jurisdiction. The parties agree that this case should be dismissed but disagree as to the grounds for such dismissal. Respondent contends that petitioners have failed to file a timely petition with this Court. Petitioners argue that the notice of deficiency is invalid on two grounds: (1) the deficiency notice was not sent...
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