Memorandum Opinion
NIMS, Chief Judge:
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction on the ground that petitioner Robert E. Joiner did not file his petition within the time prescribed by section 6213(a). In reply to respondent's motion to dismiss, petitioner asserts that the notice of deficiency is invalid on the ground that it was not mailed to his last known address. (Section references are to the Internal Revenue...
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