Memorandum Opinion
HAMBLEN, Judge:
Respondent's "Motion to Dismiss for Lack of Jurisdiction and to Strike as to Taxable Years 1978, 1979, 1981 and 1982" was filed on November 8, 1985. In his motion respondent claims that petitioner failed to file his petition within the statutory period prescribed by sections 6213(a) and 7502.
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