T.C. Summary Opinion 2001-88
UNITED STATES TAX COURT
JOHN RALPH JOHNSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 231-01S. Filed June 13, 2001.
John Ralph Johnson, pro se.
Sandra Veliz, for respondent.
LARO, Judge: This case was heard pursuant to the provisions
of section 7463 in effect at the time the petition was filed.1
Respondent moves the Court to dismiss this case for lack of
jurisdiction, asserting that petitioner failed to petition the
Court timely. Petitioner objects to respondent's motion,
1 Subsequent section references are to the Internal Revenue
Code in effect for the years in issue. Rule references are to
the Tax Court Rules of Practice and Procedure.
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