Hanna and Associates, P.C. F.K.A. Mark J. Hanna, P.C. - Page 14

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                  Because petitioner has not established that section                 
             7502 applies, we cannot find that the petition was filed                 
             within the time required by section 6213(a) and, therefore,              
             we shall grant respondent's motion to dismiss for lack of                
             jurisdiction.                                                            
                  To reflect the foregoing,                                           

                                             An appropriate order will                
                                        be entered granting respondent's              
                                        motion to dismiss.                            





























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