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As we previously indicated, petitioners received actual
notice of the deficiency from respondent. Petitioners timely
filed a petition with this Court. Therefore, the mailing of the
notice on October 6, 1999, tolled the period of limitations, and
we hold for respondent on this issue.
Conclusion
For the reasons set forth above, we shall deny petitioners’
motion to dismiss for lack of jurisdiction. In so holding, we
have carefully considered the remaining arguments made by
petitioners for a result contrary to that expressed herein, and,
to the extent not discussed above, we consider those arguments to
be without merit.
To reflect the foregoing,
An appropriate order
will be issued.
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