T.C. Memo. 2003-137
UNITED STATES TAX COURT
PAUL EVERMAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13268-02L. Filed May 14, 2003.
Jerry Arthur Jewett, for petitioner.
Michelle M. Lippert and Julie A. Pals, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the Court
on respondent’s motion to dismiss for lack of jurisdiction, as
supplemented. Respondent contends that the Court lacks
jurisdiction over the petition on the grounds that: (1) The
petition was not filed within the 90-day period prescribed in
sections 6213(a) and 7502(a); and (2) respondent did not issue to
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