T.C. Memo. 1998-149
UNITED STATES TAX COURT
CALVERT ANESTHESIA ASSOCIATES-PRICHA PHATTIYAKUL, M.D. P.A.,
Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18857-97R. Filed April 27, 1998.
Mark C. Kopec, Paul W. Madden, and Herman B. Rosenthal, for
petitioner.
Clare J. Brooks, for respondent.
MEMORANDUM OPINION
LARO, Judge: Respondent moves the Court to dismiss this
case for lack of jurisdiction, alleging that petitioner's
petition for declaratory judgment was not filed within the time
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