MEMORANDUM OPINION
COLVIN, Judge:
This case is before the Court on petitioner's motion to dismiss for lack of jurisdiction on the grounds that the notice of deficiency issued to petitioner is not valid under section 6212. Petitioner also requests that we certify this case for immediate appeal if we do not grant his motion.
Respondent determined that petitioner had an income tax deficiency of $369,390 for 1987 and was liable for additions to tax for...
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