Walter J. Hoyt, III and Betty J. Hoyt - Page 1
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T.C. Memo. 1998-292
UNITED STATES TAX COURT
WALTER J. HOYT, III AND BETTY J. HOYT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12536-97. Filed August 10, 1998.
Michael D. Culy, for petitioners.
Alan E. Staines, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: This case is before the Court on respondent's
motion to dismiss for lack of jurisdiction. Respondent bases his
motion upon the ground that the petition was not filed within the
period prescribed by section 6213(a).1
1Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended and in effect
during the relevant period, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
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