David J. and Patricia A. Fogderud - Page 1

                                  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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