T.C. Memo. 1997-376
UNITED STATES TAX COURT
HANNA AND ASSOCIATES, P.C.,
F.K.A. MARK J. HANNA, P.C., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 9716-96. Filed August 18, 1997.
Charles F. Daily, Jr., for petitioner.
Steven B. Bass, for respondent.
MEMORANDUM OPINION
WHALEN, Judge: This case is before the Court to
decide respondent's Motion To Dismiss For Lack Of
Jurisdiction. The issue for decision is whether petitioner
filed its petition within the time prescribed by section
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