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our holding in Lunsford, we hold that the notices of
determination issued to petitioners were valid.
Because the notices of determination were valid, we consider
respondent’s motion. Petitioners acknowledge in their cross-
motion to dismiss that a petition from a notice of determination
must be filed within 30 days of such a determination. The
undisputed facts underlying respondent’s motion and set forth
above compel us to conclude that this petition was untimely under
section 6330(d)(1) or 7502, and this case must be dismissed for
that reason.
An appropriate Order and
Order of Dismissal will be
entered.
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Last modified: May 25, 2011