Memorandum Findings of Fact and Opinion
GERBER, Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent contends that petitioner did not file a petition within 90 days. Petitioner counters that respondent failed to prove mailing of the notice of deficiency and/or that the notice was not mailed to petitioner's "last known address." Petitioner does not contend that a petition was timely filed.
Findings...
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