T.C. Memo. 1996-163
UNITED STATES TAX COURT
JESUS V. CUTILLAR AND NORA CUTILLAR, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent.
Docket No. 13125-95. Filed March 28, 1996.
James R. Brewster, for petitioners.
Robert Dillard, for respondent.
MEMORANDUM OPINION
RUWE, Judge: This matter is before us on respondent’s
motion to dismiss for lack of jurisdiction on the grounds that
the petition in this case was not filed within the time
prescribed by section 6213(a).1
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable year in
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