T.C. Memo. 1999-266
UNITED STATES TAX COURT
VINCENT J. AND SUSAN L. MARANTO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16364-98. Filed August 9, 1999.
Victor A. Latham, for petitioners.
Jordan Musen, for respondent.
MEMORANDUM OPINION
NAMEROFF, Special Trial Judge: This case is before the
Court on cross-motions to dismiss for lack of jurisdiction. It
was heard pursuant to section 7443A. Respondent contends that
petitioners failed to file their petition within the time
prescribed by section 6213(a),1 while petitioners contend that
1 All section references are to the Internal Revenue Code.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
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