Memorandum Findings of Fact and Opinion
JACOBS, Judge:
This case is before us on cross motions to dismiss for lack of jurisdiction. Petitioners seek dismissal on the ground that the notice of deficiency was invalid because it was not sent to their "last known address"; respondent seeks dismissal on the ground that the petition was not filed within the time prescribed by section 6213(a).
Findings of Fact
Some...
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