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Consequently, the running of the 90-day period prescribed by
section 6213(a) for filing a petition in this Court with respect
to the 1991 notice was suspended for the period during which the
automatic stay was in effect (namely, from December 15, 1994, to
May 3, 1996), and for 60 days thereafter. See sec. 6213(a),
(f)(1). Accordingly, petitioner had a total of 150 days from May
3, 1996, or until September 30, 1996, within which to file timely
a petition in this Court with respect to the 1991 notice. See
id. Petitioner filed his petition in this case on December 9,
1996. We conclude that that petition was not timely filed and
that this Court has no jurisdiction over petitioner's taxable
year 1991. See secs. 6212 and 6213.
With respect to petitioner's taxable year 1995, respondent
represents in respondent's motion, and petitioner concedes, that
respondent did not issue to petitioner a notice of deficiency for
that year. Accordingly, we conclude that this Court has no
jurisdiction over petitioner's taxable year 1995. See secs. 6212
and 6213.
To reflect the foregoing,
An appropriate Order
granting respondent's motion,
as supplemented, and dismiss-
ing this case for lack of
jurisdiction will be entered.
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Last modified: May 25, 2011