- 4 -
U.S. 694, 702 (1982); Charlotte’s Office Boutique, Inc. v.
Commissioner, 121 T.C. 89, 102 (2003), supplemented by T.C. Memo.
2004-43, affd. 425 F.3d 1203 (9th Cir. 2005); Reagoso v.
Commissioner, T.C. Memo. 1993-450, affd. without published
opinion 39 F.3d 1171 (3d Cir. 1994).
Petitioners also argue that respondent’s motion should be
denied because they are time barred from petitioning this Court
with respect to the notice of deficiency. We disagree. Because
the automatic stay was in effect when the petition was filed, the
petition is invalid and must be dismissed for lack of
jurisdiction.
An order will be issued granting
respondent’s motion and directing that
this case be dismissed for lack of
jurisdiction.
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