Memorandum Findings of Fact and Opinion
WELLS, Judge:
This case is before us on respondent's Motion to Dismiss for Lack of Jurisdiction. Respondent determined a deficiency in petitioner's Federal income tax for the taxable year 1984 in the amount of $228. Respondent seeks a dismissal on the ground that the petition was not filed within the time prescribed by sections 6213(a) and 7502.
Petitioner was a resident of Quebec...
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