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GARLAND v. COMMISSIONER

Docket No. 6939-70SC.

30 T.C.M. 326 (1971)

T.C. Memo. 1971-79

Paul Garland and Rosemary Garland v. Commissioner.

United States Tax Court.

Filed April 21, 1971.

Attorney(s) appearing for the Case

Paul Garland, pro se, 775 Potter Road, Framingham, Mass. Joel Gerber, for the respondent.

Memorandum Opinion

GUSSIS, Commissioner:

On December 11, 1970, the respondent filed a motion to dismiss this case for lack of jurisdiction because it was not filed within 90 days after the statutory notice of deficiency was mailed to petitioners, as provided by section 6213 (a) of the Internal Revenue Code of 1954.1 Petitioners objected to the motion and requested a hearing which was granted. Petitioner Paul Garland appeared...

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