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denied.
The factual issue as to whether income charged to petitioner
in respondent’s notice of deficiency represents income petitioner
earned in his individual capacity or income earned as a partner
in a TEFRA partnership does not go to the jurisdiction of this
Court.
In any event, because petitioner’s petition was filed late,
we shall grant respondent’s motion to dismiss for lack of
jurisdiction. In our discretion, we decline to award damages
against petitioner under section 6673.
To reflect the foregoing,
An appropriate order of
dismissal for lack of
jurisdiction will be entered.
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Last modified: November 10, 2007