Memorandum Opinion
SWIFT, Judge:
This case is presently before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction. The sole issue for decision is whether petitioners timely filed their petition herein as required under section 6213(a).
Petitioners Sidney M. and Claire Roth are husband and wife and resided in Beverly Hills, California, at the time of filing the petition herein. On March 28, 1986, respondent...
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