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MORGAN v. COMMISSIONER

Docket No. 2708-82.

46 T.C.M. 321 (1983)

T.C. Memo. 1983-314

James A. Morgan and Suzanne N. Morgan v. Commissioner.

United States Tax Court.

Filed June 6, 1983.

Attorney(s) appearing for the Case

Jeffrey C. Kahn, 2029 Century Park East, Los Angeles, Calif. for the petitioners. Lottie G. Wolfe, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

Both parties in this case have filed motions to dismiss for lack of jurisdiction. The petitioners claim that their motion should be granted because the deficiency notice was not sent to their last known address under section 6212(b).1 The respondent on the other hand contends that his motion should be granted because the...

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