Tim R. Casanova and San Juanita Villareal - Page 9




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          20, 1998, pertained solely to docket No. 1418-98.  In short,                
          there is no evidence in the record that petitioners mailed a                
          petition to the Court contesting the notice of deficiency for               
          1994, 1995, and 1996, on or before May 20, 1998.  Under the                 
          circumstances, we are obliged to dismiss this case for lack of              
          jurisdiction on the ground that the petition was not filed within           
          the 90-day period prescribed in section 6213(a).  See Phirman v.            
          Commissioner, T.C. Memo. 1991-431.                                          
               To reflect the foregoing,                                              


                         An order granting respondent's                               
                                        Motion to Dismiss for Lack of                 
                                        Jurisdiction will be entered.                 
























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