MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge:
This case is before the Court on respondent's motion to dismiss for lack of jurisdiction (the motion). Petitioners object. Respondent's grounds are that the petition was not filed within the time prescribed by section 6330(d)(1)(A). An evidentiary hearing was held in Detroit, Michigan, on June 10, 2002, at which testimony was taken and other evidence...
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