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.
Phillips.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011