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.Page: 1 2 3 4 5 6 7 Next
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