T.C. Memo. 1999-13
UNITED STATES TAX COURT
DAVID J. AND PATRICIA A. FOGDERUD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5197-98. Filed January 25, 1999.
Michael F. O'Donnell, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This case comes before the
Court on respondent's motion to dismiss for lack of jurisdiction
on the ground that the petition was not filed within the time
prescribed by sections 6213(a) or 7502. This case was heard
pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. All
section references are to the Internal Revenue Code for the years
in issue. All Rule references are to the Tax Court Rules of
Practice and Procedure.
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