OPINION
HALPERN, Judge:
Each of the parties has filed a motion asking us to dismiss this case for lack of jurisdiction. Respondent has filed her motion on the ground that petitioner failed to file timely the petition in this case. Petitioner has filed her motion on the ground that respondent's notice of deficiency is invalid. For the reasons set forth, we grant petitioner's motion.
Background
At a hearing on the respective...
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