Memorandum Findings of Fact and Opinion
HALPERN, Judge:
By notice of deficiency dated June 19, 1992, respondent has determined income tax deficiencies of $5,120 and $216 for 1983 and 1984, respectively, along with an addition to tax under section 6661 of $1,280 for 1983.
The sole issue raised by the parties is whether we should grant respondent's motion to dismiss, on the ground that the prior assessment of those amounts rendered the deficiency notice...
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