Gregory Keith Wade - Page 1

                                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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