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.Page: 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011