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SPIVEY v. COMMISSIONER

Docket No. 19180-99.

81 T.C.M. 1117 (2001)

T.C. Memo. 2001-29

John D. Spivey and Pamela K. Spivey v. Commissioner.

United States Tax Court.

Filed February 8, 2001.

Attorney(s) appearing for the Case

David D. Aughtry and Brett W. Beveridge, for the petitioners.

Gwendolyn C. Walker, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

This case is before us on cross-motions to dismiss for lack of jurisdiction (cross-motions). On September 11, 2000, the Court held a hearing (hearing) on the parties' cross-motions.

Petitioners moved to dismiss this case for lack of jurisdiction on the following alternative grounds: (1) No notice of deficiency was mailed to petitioners, and (2) any notice of deficiency mailed to petitioners...

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