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ARMSTRONG v. COMMISSIONER

Docket No. 30480-83.

59 T.C.M. 405 (1990)

T.C. Memo. 1990-191

Clarence Armstrong, Jr. and Dorothy L. Armstrong v. Commissioner.

United States Tax Court.

Filed April 11, 1990.

Attorney(s) appearing for the Case

John Harrison Wegge, 909 Green St., Pasadena, Calif., for the petitioners. Ross Paulson, Monica Melgarejo, and John Kent, for the respondent.

Memorandum Findings of Fact and Opinion

PANUTHOS, Special Trial Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction.1 Since there is no question that the petition was not timely filed, the issue for decision is whether respondent mailed the notice of deficiency to petitioners' "last known address."

Findngs of Fact

Respondent issued a notice of deficiency dated April...

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