Memorandum Findings of Fact and Opinion
POWELL, Special Trial Judge:
This case was assigned pursuant to the provisions of section 7456(d) (redesignated as section 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2755) and Rule 180 et seq. This case is before the Court on petitioners' motion to dismiss. The gravamen of that motion is that the statutory notice for the 1980 taxable year is invalid. The facts are as follows.
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