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CASSELL v. COMMISSIONER

Docket No. 9342-78.

72 T.C. 313 (1979)

ORTHEL E. CASSELL, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 10, 1979.

Attorney(s) appearing for the Case

Orthel E. Cassell, pro se.

Robert P. Edler, for the respondent.

OPINION

DRENNEN, Judge:

This case is before us on respondent's motion to dismiss for lack of jurisdiction upon the ground that the petition was not filed within the time prescribed by section 6213(a), I.R.C. 1954.1 In this case that time was "within 90 days * * * after the notice of deficiency * * * is mailed."

Petitioner resided in St. Louis, Mo., when the "petition" herein was filed. Respondent mailed a notice...

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