- 9 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011