T.C. Memo. 1998-24
UNITED STATES TAX COURT
NEAL A. SANDERS, d.b.a. LAW OFFICES OF NEAL A. SANDERS,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 128-97. Filed January 21, 1998.
Neal Alan Sanders, pro se.
Peter J. Gavagan, for respondent.
MEMORANDUM OPINION
JACOBS, Judge: This matter is before the Court on the
parties' cross-motions to dismiss for lack of jurisdiction.
Respondent moves to dismiss this case as to income tax deficiencies
for 1992 and 1993 for lack of jurisdiction on the grounds that the
amended petition (in which the allegations concerning those income
tax deficiencies were first raised) was filed more than 90 days
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