- 10 -
Memo. 1994-32; Vanderstappen v. Commissioner, T.C. Memo. 1993-
109; see also Lindemood v. Commissioner, 566 F.2d 646 (9th Cir.
1977), affg. per curiam T.C. Memo. 1975-195.
Because petitioners have failed to show that they meet the
requirements of section 301.7502-1(c), Proced. & Admin. Regs.,
the petition is not rendered timely by section 7502 and therefore
was not timely filed under section 6213(a). Accordingly, we
grant respondent's motion to dismiss for lack of jurisdiction on
the ground that the petition was not timely filed.
To reflect the foregoing,
An appropriate order of dismissal
for lack of jurisdiction will be
entered.
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