T.C. Memo. 1997-303
UNITED STATES TAX COURT
GERRY DAN AND KELLY M. LANGSTON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22262-96. Filed July 1, 1997.
James D. Williams, for petitioners.
Ann L. Darnold, for respondent.
MEMORANDUM OPINION
COUVILLION, Special Trial Judge: Respondent filed a motion
to dismiss this case for lack of jurisdiction on the ground that
the petition was not timely filed. Petitioners, through counsel,
filed a notice of objection. The motion was assigned for hearing
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