MEMORANDUM OPINION
ARMEN, Special Trial Judge:
This matter is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction, filed May 1, 2000. As discussed in detail below, we shall grant respondent's motion to dismiss.
Background
On December 2, 1999, respondent mailed a notice of deficiency to Michael H. and Barbara Selter (the Selters or petitioners) determining a deficiency of $31,970 in their Federal income tax...
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