Charles T. and Joan B. Phillips - Page 1

                                 T.C. Memo. 1996-196                                  

                               UNITED STATES TAX COURT                                

                   CHARLES T. AND JOAN B. PHILLIPS, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4706-94.                    Filed April 23, 1996.           

               Thomas E. Redding and Sallie W. Gladney, for petitioners.              
               John F. Eiman and Thomas Fenner, for respondent.                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               FAY, Judge:  This case is before the Court on the parties'             
          cross-motions to dismiss for lack of jurisdiction.  The parties             
          have stipulated that petitioners1 filed a petition with the U.S.            
          Tax Court on March 21, 1994, more than 90 days after both notices           
          of deficiency were mailed.  On May 20, 1994, respondent filed a             

          1All references to petitioner are to Mr. Charles T.                         

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