Memorandum Findings of Fact and Opinion
NIMS, Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction and to strike as to the taxable year 1986, petitioner having petitioned for a redetermination of respondent's determinations for both 1986 and 1987. Respondent argues that, as to 1986, the petition was not timely filed. Petitioner does not dispute that claim but contends that the notice of deficiency is invalid because...
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