Paul Everman - Page 1

                                 T.C. Memo. 2003-137                                  

                               UNITED STATES TAX COURT                                

                             PAUL EVERMAN, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13268-02L.            Filed May 14, 2003.                   

               Jerry Arthur Jewett, for petitioner.                                   
               Michelle M. Lippert and Julie A. Pals, for respondent.                 

                                 MEMORANDUM OPINION                                   

               ARMEN, Special Trial Judge:  This matter is before the Court           
          on respondent’s motion to dismiss for lack of jurisdiction, as              
          supplemented.  Respondent contends that the Court lacks                     
          jurisdiction over the petition on the grounds that: (1) The                 
          petition was not filed within the 90-day period prescribed in               
          sections 6213(a) and 7502(a); and (2) respondent did not issue to           

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