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JUDD v. COMMISSIONER

Docket No. 23024-88.

59 T.C.M. 663 (1990)

T.C. Memo. 1990-253

Lewis B. Judd and Vivienne Judd v. Commissioner.

United States Tax Court.

Filed May 23, 1990.

Attorney(s) appearing for the Case

William F. De Francis, 120 N. Main St., New City, N.Y., for the petitioners. Robert W. Sadowski, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

This matter is before us to consider petitioners' Motion to Dismiss For Untimely Receipt of Notice of Deficiency (Motion to Dismiss for Lack of Jurisdiction), filed November 6, 1989. The issues for consideration are: (1) Whether petitioners' receipt (other than by mail) of a notice of deficiency which had been mailed, but not addressed to their "last known address," at a time when the period for assessment...

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