Rosie Burnside - Page 1
















                                 T.C. Memo. 1999-85                                   


                               UNITED STATES TAX COURT                                


                            ROSIE BURNSIDE, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 8305-98.                   Filed March 23, 1999.            


               Rosie Burnside, pro se.                                                
               Peter C. Rock and Paul R. Zamolo, for respondent.                      

                                 MEMORANDUM OPINION                                   
               VASQUEZ, Judge:  This matter is before the Court on                    
          respondent's motion to dismiss for lack of jurisdiction.  The               
          issue presented is whether petitioner had 90 or 150 days within             
          which to file her petition to this Court under section 6213(a).1            
          Background                                                                  

               1  All section references are to the Internal Revenue Code             
          in effect for the years in issue.                                           




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