T.C. Memo. 2001-230
UNITED STATES TAX COURT
MOSHE ROTHBARD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 398-01. Filed August 23, 2001.
Leo Salzman (specially recognized), for petitioner.
Michael A. Menillo, for respondent.
MEMORANDUM OPINION
CHIECHI, Judge: This case is before us on respondent’s
motion to dismiss for lack of jurisdiction (respondent’s motion)
because the petition was not timely filed. The Court held an
evidentiary hearing on respondent’s motion.
In the petition, petitioner indicated that his principal
residence as of the date the petition was filed was in Manches-
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