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Under these circumstances, we conclude that the petition was
not filed within the requisite period prescribed by section
6213(a). Consequently, this case must be dismissed for lack of
jurisdiction.8
To reflect the foregoing,
An order granting
respondent’s motion as
supplemented and dismissing
this case for lack of
jurisdiction because of an
untimely filed petition will
be entered.
8 Although petitioner cannot pursue her case in this Court,
she is not without a judicial remedy. Specifically, petitioner
may pay the tax, file a claim for refund with the Internal
Revenue Service, and, if her claim is denied, sue for a refund in
the appropriate Federal District Court or the U.S. Court of
Federal Claims. See McCormick v. Commissioner, 55 T.C. 138, 142
n.5 (1970).
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