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BRIGGS v. COMMISSIONER

Docket No. 38310-86.

55 T.C.M. 487 (1988)

T.C. Memo. 1988-130

William C. and Therese M. Briggs v. Commissioner.

United States Tax Court.

Filed March 28, 1988.

Attorney(s) appearing for the Case

Jeffrey P. Berg, Michael R. Matthias, and Robert D. Bergman, for the petitioners. Stephen M. Miller, for the respondent.

Memorandum Opinion

SWIFT, Judge:

This matter is before the Court on petitioners' motion to dismiss for lack of jurisdiction which we will treat as a motion for summary judgment.1 We must decide whether respondent timely issued his notice of deficiency for 1982 in accordance with section 6501(a).2 Petitioners resided in Cleveland, Ohio at the time their petition was filed.

Petitioners' joint...

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