Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined a $10,016 deficiency in petitioner's 1976 Federal income tax. This proceeding arises from respondent's motion to dismiss for lack of jurisdiction on the ground that the petition to this Court for redetermination of deficiency was not timely filed by petitioner.
Findings of Fact
Some of the facts have been stipulated and are found accordingly.
Petitioner...
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