- 7 -
571 F.2d 1306, 1309-1310 (4th Cir. 1978); Woods v. Commissioner,
T.C. Memo. 1991-433, affd. without published opinion 967 F.2d 597
(9th Cir. 1992).
Consistent with the foregoing, we shall grant respondent's
motion to dismiss for lack of jurisdiction on the ground that
petitioner failed to file a timely petition for redetermination.6
To reflect the foregoing,
An order granting
respondent's Motion to Dismiss
for Lack of Jurisdiction will
be entered.
6 Although petitioner cannot pursue his case in this Court,
he is not without a legal remedy. In short, petitioner may pay
the tax, file a claim for refund with the Internal Revenue
Service, and if the claim is denied, sue for a refund in the
Federal District Court or the U.S. Court of Federal Claims. See
McCormick v. Commissioner, 55 T.C. 138, 142 (1970).
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