T.C. Memo. 2006-26
UNITED STATES TAX COURT
ROBERT MUSSELMAN AND ADRIANNE MAGD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7170-05. Filed February 15, 2006.
Robert Musselman and Adrianne Magd, pro sese.
Loren B. Mark, for respondent.
MEMORANDUM OPINION
LARO, Judge: This case is before the Court on respondent’s
motion to dismiss for lack of jurisdiction on the ground that
petitioners failed to file their petition within the time
prescribed in section 6213(a) or 7502.1 On April 18, 2005,
1 Section references are to the applicable versions of the
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