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