T.C. Memo. 2005-35
UNITED STATES TAX COURT
MICHAEL AND MARION BALICE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5437-04L. Filed February 28, 2005.
Frank J. Marcone (specially recognized), for petitioners.
Kathleen Raup, for respondent.
MEMORANDUM OPINION
MARVEL, Judge: This matter is before the Court on
respondent’s motion to dismiss for lack of jurisdiction on the
ground that the petition was not filed within the time prescribed
by section 6330(d)(1)1 or section 7502.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at the time petitioners filed
the petition.
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