T.C. Memo. 2000-209
UNITED STATES TAX COURT
JOHN L. & LISA K. ERICKSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12436-99. Filed July 7, 2000.
Todd R. Cannon, for petitioners.
Melinda G. Williams, Richard W. Kennedy, and Gregory M.
Hahn, for respondent.
MEMORANDUM OPINION
COHEN, Judge: This case is before the Court on respondent's
Motion to Dismiss for Lack of Jurisdiction on the ground that the
petition was not filed within the 90-day period prescribed in
section 6213(a). Unless otherwise indicated, all section
references are to the Internal Revenue Code in effect for the
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