WHALEN, Judge:
This case is before the Court to decide the cross-motions of the parties to dismiss for lack of jurisdiction. The dispositive issue is whether respondent mailed the notice of deficiency to the "last known address" of both petitioners, as contemplated by section 6212.
FINDINGS OF FACT
Some of the facts have been stipulated, and are so found. The stipulation of facts filed by the parties and the exhibits...
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