T.C. Memo. 1998-293
UNITED STATES TAX COURT
WALTER J. HOYT, IV AND CYNTHIA M. WITT-HOYT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13648-97. Filed August 10, 1998.
Raymond Jackson and Michael D. Culy, for petitioners.
Alan E. Staines, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: This case is before the Court on respondent's
motion to dismiss for lack of jurisdiction. Respondent bases his
motion on the ground that the petition was not filed within the
period prescribed by section 6213(a).1
1Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended and in effect
during the relevant period, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
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