Memorandum Opinion
FAY, Judge:
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction and to strike as to the 1984 taxable year. The issue is whether the petition was timely filed with respect to the 1984 taxable year.
At the time the petition in this matter was filed, petitioners resided in Colorado Springs, Colorado.
On December 5, 1986, respondent sent petitioners a notice of deficiency in the amount...
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