Memorandum Opinion
GERBER, Judge:
Respondent, on September 10, 1985, mailed a notice of deficiency to petitioners concerning their 1982 and 1983 taxable years. On January 2, 1990, the petition was filed with this Court seeking our jurisdiction and urging us to decide that respondent failed to mail a timely notice of deficiency. Petitioners do not contend that the petition was timely, but instead argue that in the circumstances of this case we should find...
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