T.C. Memo. 1996-478
UNITED STATES TAX COURT
ESTATE OF ANTONINO CAMPILONGO, DECEASED, RAFELINA MAGLIO,
EXECUTRIX, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6122-95. Filed October 23, 1996.
Stephen C. Ryan and Andrew H. Wilson, for petitioner.
Cynthia K. Hustad and Elaine L. Sierra, for respondent.
MEMORANDUM OPINION
JACOBS, Judge: This matter is before the Court on
respondent's motion to dismiss for lack of jurisdiction.
Respondent contends that the petition was not filed within the 90-
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