T.C. Memo. 1998-159
UNITED STATES TAX COURT
GLEN A. FINNELL, Petitioner v. COMMISSIONER OF
INTERNAL REVENUE, Respondent
Docket No. 17870-97R. Filed May 4, 1998.
Glen A. Finnell, pro se.
William I. Miller, 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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