T.C. Memo. 1998-235
UNITED STATES TAX COURT
GREGORY KEITH WADE, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17766-97. Filed July 2, 1998.
Gregory Keith Wade, pro se.
Paul B. Burns, for respondent.
MEMORANDUM OPINION
WOLFE, Special Trial Judge: This matter is before the Court
on respondent's Motion to Dismiss for Lack of Jurisdiction.
Respondent contends that this Court lacks jurisdiction because
the petition was not filed within the applicable 90-day period
after mailing of the deficiency notice as required by sections
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