Memorandum Opinion
HALPERN, Judge:
These five cases were consolidated for the limited purpose of hearing and ruling on the motions pending before us. The issue in each case involves petitioners' interest in a computer leasing program or computer equipment acquired in 1985. In docket Nos. 15084-89, 15620-89, and 19723-89, respondent moved to dismiss for lack of jurisdiction on the grounds that notices of deficiency issued therein for the year 1985 are invalid...
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