Memorandum Findings of Fact and Opinion
KÖRNER, Judge:
This matter is before the Court on cross-motions by the parties to dismiss for lack of jurisdiction. Respondent's motion to dismiss is based upon the alleged failure of petitioner to file her petition with this Court within 90 days of the issuance of respondent's statutory notice of deficiency for the years 1978 and 1979, as required by section 6213.
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