Frank Blazic - Page 1

                                       T.C. Memo. 2000-313                                             

                                     UNITED STATES TAX COURT                                           

                           FRANK BLAZIC, Petitioner v. COMMISSIONER                                    
                                OF INTERNAL REVENUE, Respondent                                        

                  Docket No. 14503-99.                  Filed October 3, 2000.                         

                  John Gigounas, for petitioner.                                                       
                  Daniel J. Parent, for respondent.                                                    

                                        MEMORANDUM OPINION                                             
                  CARLUZZO, Special Trial Judge:  This case is before the                              
            Court on respondent’s Motion to Dismiss for Lack of Jurisdiction,                          
            filed December 16, 1999.  Respondent’s motion is based upon the                            
            ground that the petition in this case was not filed within the                             
            period prescribed by section 6213(a).1  In petitioner’s                                    

                  1 Section references are to the Internal Revenue Code of                             
            1986, as amended.                                                                          

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