T.C. Memo. 1998-118
UNITED STATES TAX COURT
PATRICK ANTHONY MASINO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 14987-96. Filed March 25, 1998.
Patrick A. Masino, pro se.
Steven M. Roth, for respondent.
MEMORANDUM OPINION
GERBER, Judge: This case is before the Court on
respondent’s Motion to Dismiss for Lack of Jurisdiction, filed
August 13, 1997. Respondent contends that this case should be
dismissed because the petition was not filed within 90 days after
the notice of deficiency was mailed pursuant to section 6213(a).1
1 All section references are to the Internal Revenue Code in
(continued...)
Page: 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011