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GAYLE v. BLAZ

Civ. No. 74-114.

432 F.Supp. 1167 (1977)

Andrew M. and Maria C. GAYLE, Petitioners, v. Joaquin G. BLAZ, Director, Department of Revenue & Taxation, Respondent.

District Court of Guam, Agana, Guam.

April 27, 1977.

Attorney(s) appearing for the Case

Howard G. Trapp, Trapp, Gayle, Teker, Hammer, Lacy & Moore, Agana, Guam, for petitioners.

Philip H. Jacobsen, Deputy Atty. Gen., Agana, Guam, for respondent.

MEMORANDUM ORDER

DUENAS, District Judge.

Petitioners received a notice of deficiency from the Director of Revenue & Taxation dated February 12, 1974. On May 15, 1974 Petitioners filed with this Court a Petition for Determination of Proposed Deficiencies. Respondent has filed a motion to dismiss the petition for lack of jurisdiction on the ground that the petition was untimely filed.

26 U.S.C.A. Sec...

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