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RUEGSEGGER v. COMMISSIONER

Docket No. 3057-76.

68 T.C. 463 (1977)

PAUL RUEGSEGGER AND FREYA D. RUEGSEGGER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 11, 1977.

Attorney(s) appearing for the Case

Warren Kahn, for the petitioners.

Jack H. Klinghoffer, for the respondent.

OPINION

IRWIN, Judge:

This matter is before us on respondent's "Motion to Dismiss for Lack of Jurisdiction" filed May 25, 1976. It is respondent's contention that the petition in this case was not filed within the time prescribed by section 6213(a) of the Internal Revenue Code of 1954.1

Respondent mailed a statutory notice of deficiency to petitioners on January 9, 1976. The last day for timely filing a petition...

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