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
respondent.
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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