Edward K. & Susie Y. Wong - Page 9




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          Additionally, petitioners did not even begin to discuss audit               
          reconsideration with respondent until after the 90-day period had           
          expired.                                                                    
               We find that petitioners did not file their petition for               
          redetermination with this Court within the time prescribed by               
          sections 6213(a) and 7502.  Therefore, we lack jurisdiction to              
          redetermine the 1995 tax liability of petitioners.  We grant                
          respondent's motion to dismiss for lack of jurisdiction.                    
               To the extent we did not discuss any of the parties'                   
          arguments, we have considered them and find them to be without              
          merit.                                                                      
               To reflect the foregoing,                                              


                                             An order granting respondent's           
                                        motion to dismiss for lack of                 
                                        jurisdiction will be entered.                 




















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