MEMORANDUM FINDINGS OF FACT AND OPINION
WHALEN, Judge:
This case is before the Court to decide cross-motions to dismiss for lack of jurisdiction. Respondent's motion argues that the instant petition for readjustment must be dismissed because petitioners failed to file the petition within the time required by section 6226(b). All section references are to the Internal Revenue Code as amended. Petitioners' motion argues that the petition must be dismissed...
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