Memorandum Findings of Fact and Opinion
COLVIN, Judge:
This case is before the Court on petitioner's motions to dismiss for lack of jurisdiction and to enjoin collection proceedings and respondent's cross-motion to dismiss for lack of jurisdiction. The issue for decision is whether the notice of deficiency was mailed to petitioner's last known address. Petitioner filed a return 43 days before the issuance of the notice of deficiency. We hold that respondent...
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