T.C. Memo. 2005-148
UNITED STATES TAX COURT
DAVID BROOMFIELD, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4849-03L. Filed June 21, 2005.
David Broomfield, pro se.
Mark D. Petersen, for respondent.
MEMORANDUM OPINION
GALE, Judge: This case 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
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