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FISHMAN v. COMMISSIONER

Docket No. 4587-67.

51 T.C. 869 (1969)

IRVING FISHMAN AND HELEN FISHMAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 27, 1969.

Attorney(s) appearing for the Case

Morton L. Ginsberg, for the petitioners.

Wallace Musoff, for the respondent.

OPINION

SIMPSON, Judge:

On November 7, 1967, the respondent filed a motion to dismiss the petition in this case for lack of jurisdiction because the petition was not filed within 90 days after the mailing of the deficiency notice. Sec. 6213, I.R.C. 1954.1 The controversy revolves about the construction and validity of regulations relating to the filing of documents by metered mail. Written and oral evidence has been presented...

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