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JOSEPH v. COMMISSIONER

Docket No. 1320-90.

61 T.C.M. 2056 (1991)

T.C. Memo. 1991-94

Davis B. Joseph and Helen M. Joseph v. Commissioner.

United States Tax Court.

Filed March 5, 1991.

Attorney(s) appearing for the Case

Alexander B. McDonald, for the petitioners. Caroline Arnold, for the respondent.

Memorandum Opinion

PANUTHOS, Special Trial Judge:

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. The issue for decision is whether the notice of deficiency was mailed to petitioners' "last known address" within the meaning of section 6212(b).1

The facts have been stipulated and are so found. Petitioners' 1981 and 1982 Federal income tax returns were filed in March 1984. The address...

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