Walter J. Hoyt, III and Betty J. Hoyt - Page 1

                                 T.C. Memo. 1998-292                                  

                              UNITED STATES TAX COURT                                

                WALTER J. HOYT, III AND BETTY J. HOYT, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12536-97.                  Filed August 10, 1998.           

               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 upon 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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