Memorandum Opinion
SCOTT, Judge:
On November 4, 1991, petitioners filed a motion to dismiss this case for lack of jurisdiction on the grounds that respondent's notice of deficiency was untimely since it was not mailed to petitioners within 3 years from the date of the filing of petitioners' return for the year ended December 31, 1984, here involved. Petitioners alleged that they had not extended the period of limitations for the assessment of tax for the...
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