OPINION
WILLIAMS, Judge:
This case is before us on petitioners' motion to dismiss for lack of jurisdiction. The issue we must decide is whether respondent determined a deficiency in petitioners' 1983 Federal income tax.
The facts have been fully stipulated and are so found. Petitioners were husband and wife during the year in issue and resided in Montecito, California, at the time the petition was filed in this case.
On their 1983...
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