- 10 - 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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