Robert Musselman and Adrianne Magd - Page 1

                                 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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