Michael R. and Sheila Olsen - Page 1

                                 T.C. Memo. 2002-206                                  

                               UNITED STATES TAX COURT                                

                  MICHAEL R. OLSEN AND SHEILA OLSEN, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 4950-02.               Filed August 16, 2002.               

               Michael R. Olsen and Sheila Olsen, pro sese.                           
               Christian A. Speck and William A. Heard III, for                       

                                 MEMORANDUM OPINION                                   
               ARMEN, Special Trial Judge:  This matter is before the Court           
          on respondent’s Motion to Dismiss for Lack of Jurisdiction.                 
          Respondent contends that this case should be dismissed on the               
          ground that the petition was not timely filed pursuant to section           

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