MEMORANDUM OPINION
ARMEN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.
This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction, filed pursuant to Rule 53. The issue that we must decide is whether petitioners filed their petition with the Court within the time period prescribed by section 6213(a).
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