MEMORANDUM OPINION
GALE, Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. The issue for decision is whether petitioners filed their petition for redetermination within the 90-day period prescribed by section 6213(a).
Background
On August 7, 1996, respondent issued and mailed to petitioners a statutory notice of deficiency determining a deficiency of $160...
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