Jesus V. Cutillar and Nora Cutillar - Page 6

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               Petitioners were not entitled to avail themselves of the               
          150-day filing period.  Accordingly, respondent’s motion to                 
          dismiss will be granted.3                                                   


                                                An appropriate order of              
                                             dismissal will be entered.               
























               3Petitioners also make a generalized claim that they were              
          denied due process during the partnership level proceeding.  The            
          partnership level proceeding preceded and was completed prior to            
          the notices of deficiency upon which the petition in the instant            
          case was based.  Our jurisdiction to consider any of petitioners’           
          arguments must be based upon a timely petition.  As we have held,           
          we lack jurisdiction because the petition in this case was not              
          filed within the statutory time limit.                                      





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