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Accordingly, we hold that the notices are valid from the
date of their mailing and that the 90-day filing period in the
instant cases therefore began on June 7, 1996, the date of the
mailing of the notices of deficiency. As the petitions in the
instant cases were not timely filed, we grant respondent's
motions to dismiss.
To reflect the foregoing,
Appropriate orders will
be entered.
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Last modified: May 25, 2011