Edward C. and Margaret C. Chang - Page 10

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          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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