MEMORANDUM OPINION
GALE, Judge:
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent's motion contends that the Court lacks jurisdiction because the petition was not timely filed. Petitioner argues that the notice of deficiency was invalid because it was not mailed to his "last known address"; that respondent's failure to use the last known address is not cured by petitioner's actual receipt, because petitioner...
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