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BROWN v. COMMISSIONER

Docket No. 19384-81.

43 T.C.M. 954 (1982)

T.C. Memo. 1982-165

Howard S. Brown and Jacqueline R. Brown v. Commissioner.

United States Tax Court.

Filed March 30, 1982.

Attorney(s) appearing for the Case

Jeffrey A. King, for the petitioners. Judy K. Hunt, for the respondent.

Memorandum Opinion

SIMPSON, Judge:

This matter is before us on the Commissioner's motion to dismiss this case for lack of jurisdiction. It is the Commissioner's contention that the petition in this case was not filed within the time prescribed by section 6213(a) of the Internal Revenue Code of 1954.1

On April 15, 1981, the Commissioner mailed a statutory notice of deficiency to the petitioners at their last known address...

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