Memorandum Opinion
RUWE, Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction as to the taxable years 1989 and 1990. The sole issue for decision is whether the notice of deficiency was mailed to petitioner's "last known address" within the meaning of section 6212(b).
When this matter was called for an evidentiary hearing, the parties informed the Court that they wanted this...
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