Memorandum Opinion
WHALEN, Judge:
This case is before the Court to decide respondent's Motion to Dismiss for Lack of Jurisdiction in which he contends that the petition is untimely as to some, but not all, of the years for which relief is requested therein. Petitioner objects to respondent's motion on the ground that the notices of deficiency for the years covered by respondent's motion were not sent to his "last known address" within the meaning of section...
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