Memorandum Findings of Fact and Opinion
JACOBS, Judge:
This matter is before the Court on cross-motions to dismiss for lack of jurisdiction. Petitioners' motion is premised upon respondent's alleged failure to mail the notice of deficiency to petitioners at their last known address. Alternatively, petitioners contend that as a result of actions taken by respondent which interrupted the delivery of the notice to them, either (1) the mailing of the notice...
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