Memorandum Opinion
RUWE, Judge.
This case is before the Court on cross-motions to dismiss for lack of jurisdiction as to taxable years 1985 and 1986. The sole issue presented by the cross-motions is whether the notice of deficiency was mailed to petitioner's "last known address" within the meaning of section 6212(b).
The parties submitted this case fully stipulated. The stipulation of facts and attached exhibits are...
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