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TEEL v. COMMISSIONER

Docket No. 60204.

27 T.C. 375 (1956)

THERON C. TEEL AND LYNN W. TEEL, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 27, 1956.

Attorney(s) appearing for the Case

Thomas E. Tyre, Esq., for the respondent.

OPINION.

MURDOCK, Judge:

The Commissioner moved to dismiss this proceeding for lack of jurisdiction because the petition, which was filed November 18, 1955, was not filed within 90 days after the mailing of the notice of deficiency as required by section 6213 (a) of the Internal Revenue Code of 1954. The only dispute is with respect to the beginning of the 90-day period, that is, the date when the notice of deficiency must be regarded as having been...

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