Memorandum Opinion
WELLS, Judge:
This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction. Respondent seeks dismissal on the ground that the petition was not filed within the time prescribed by section 6213(a) or 7502.
In his notice of deficiency, dated March 5, 1986, respondent determined a deficiency in income tax for the taxable year 1982 in the amount of $26,818 as well as additions...
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