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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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