Memorandum Opinion
HAMBLEN, Judge:
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction on the ground that the petition was not timely filed. The issues to be decided are (1) whether respondent's notice of deficiency was timely mailed to petitioner's last known address and, if so, (2) whether the petition was timely filed.
An evidentiary hearing was held on respondent's motion in Detroit, Michigan. Based on the...
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