T.C. Memo. 2000-231
UNITED STATES TAX COURT
HOWARD M. MORGAN AND GLENICE S. MORGAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17424-99. Filed August 1, 2000.
Frank A. Weiser, for petitioners.
Edwin A. Herrera, for respondent.
MEMORANDUM OPINION
LARO, Judge: Respondent moves the Court to dismiss this
case for lack of jurisdiction arguing that petitioners failed to
petition this Court within the 90-day period of section 6213(a)1.
1Unless otherwise indicated, section references are to the
Internal Revenue Code as applicable herein. Rule references are
to the Tax Court Rules of Practice and Procedure.
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