Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders - Page 1

                                 T.C. Memo. 1998-24                                   

                               UNITED STATES TAX COURT                                

          NEAL A. SANDERS, d.b.a. LAW OFFICES OF NEAL A. SANDERS,                     
             Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent               

               Docket No. 128-97.                   Filed January 21, 1998.           

               Neal Alan Sanders, pro se.                                             
               Peter J. Gavagan, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               JACOBS, Judge:  This matter is before the Court on the                 
          parties' cross-motions to dismiss for lack of jurisdiction.                 
          Respondent moves to dismiss this case as to income tax deficiencies         
          for 1992 and 1993 for lack of jurisdiction on the grounds that the          
          amended petition (in which the allegations concerning those income          
          tax deficiencies were first raised) was filed more than 90 days             

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