T.C. Memo. 2000-88
UNITED STATES TAX COURT
EDWARD K. & SUSIE Y. WONG, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6918-99. Filed March 14, 2000.
Edward K. Wong, pro se.
Sylvia L. Shaughnessy and Jenny A. Moon, 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 grounds that the petition was not filed within the time
prescribed by section 6213(a) or section 7502. Unless otherwise
indicated, section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
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