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ANDREWS v. COMMISSIONER

Docket No. 18670-96.

76 T.C.M. 501 (1998)

T.C. Memo. 1998-339

James A. and Muriel M. Andrews v. Commissioner.

United States Tax Court.

Filed September 23, 1998.

Attorney(s) appearing for the Case

Bernard S. Mark and Richard S. Kestenbaum, for the petitioners. Catherine R. Chastanet, for the respondent.

MEMORANDUM OPINION

GALE, Judge:

This case is before the Court on petitioners' and respondent's motions to dismiss for lack of jurisdiction. The issue is whether the notice of deficiency in this case was mailed to petitioners' "last known address" for purposes of section 6212(b)(1).1 Respondent argues that the notice of deficiency in this case was mailed to petitioners' last known address and that the petition was untimely because...

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