Memorandum Opinion
NAMEROFF, Special Trial Judge:
This case is before the Court on petitioners' Motion to Dismiss Taxable Year 1982 for Lack of Jurisdiction. In a notice of deficiency mailed March 27, 1986, respondent determined the following deficiencies and additions to tax for the taxable years 1980, 1981 and 1982:
Additions to Tax --------------------------------- Year ...
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