T.C. Memo. 2002-193
UNITED STATES TAX COURT
TIMOTHY SCOTT AND ANYA FRANCES ANTHONY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12818-01. Filed August 6, 2002.
Timothy Scott Anthony, pro se.
David Lau, for respondent.
MEMORANDUM OPINION
COLVIN, Judge: This matter is before the Court on
respondent’s motion to dismiss for lack of jurisdiction on the
ground that the petition was untimely.
Petitioners mailed their petition on October 3, 2001, which
was 98 days after respondent mailed the notice of deficiency.
The sole issue for decision is whether the time for petitioners
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