T.C. Memo. 2001-156
UNITED STATES TAX COURT
MICHAEL RISING SUN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1524-00. Filed June 28, 2001.
Michael Rising Sun, pro se.
Christa Gruber and Ann M. Welhaf, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This case is before the Court
on respondent's motion to dismiss for lack of jurisdiction on the
ground that the petition was not filed within the time prescribed
by section 6213(a) and section 7502. Unless otherwise indicated,
section references are to the Internal Revenue Code in effect for
the years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
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