Neal A. Sanders, d.b.a. Law Offices of Neal A. Sanders - Page 10

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                    than one person, each such person desiring to                     
                    contest it shall file a petition, either                          
                    separately or jointly with any such other                         
                    person, and each such person must satisfy all                     
                    the requirements of this Rule in order for the                    
                    petition to be treated as filed by or for such                    
                    person.  The petition shall be complete, so as                    
                    to enable ascertainment of the issues intended                    
                    to be presented. * * * Failure of the petition                    
                    to satisfy applicable requirements may be                         
                    ground for dismissal of the case. * * *                           
          Rule 34(a).                                                                 
               Section 6213(a) provides that in general a petition must be            
          filed within 90 days after the notice of deficiency authorized under        
          section 6212(a) is mailed.  Our jurisdiction is narrowly defined by         
          statute, and we have no power to extend the 90-day period for filing        
          a petition.  Rule 25(c); see Pyo v. Commissioner, 83 T.C. 626, 632          
          (1984).  Here, the 90-day period for filing a timely petition               
          expired on January 9, 1997--a date that is before the date the              
          amended petition was filed.                                                 
               We agree with respondent that the original petition (that is,          
          the petition filed on January 2, 1997) did not indicate that                
          petitioner was contesting respondent's income tax determinations and        
          accuracy-related penalties for 1992 and 1993, as set forth in the           
          third deficiency notice.  There was no mention of income taxes in           
          that part of the petition informing us as to the nature of the case,        
          nor could we ascertain from the caption of the case that Mr. Sanders        
          intended to contest respondent's determination in any capacity other        
          than as it related to his law firm.  Other than a statement in the          





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