Thomas and Iris Tilley - Page 8




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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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