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CASSIDY v. COMMISSIONER

Docket No. 22637-81.

44 T.C.M. 507 (1982)

T.C. Memo. 1982-406

Jack E. Cassidy (deceased) by Joseph A. Cassidy and Jerry Bock, as executors of the estate of Jack E. Cassidy, and Shirley Jones Cassidy v. Commissioner.

United States Tax Court.

Filed July 19, 1982.

Attorney(s) appearing for the Case

David L. Blender and Marshall N. Schwartz, 16255 Ventura Blvd., Encino, Calif., for the petitioners. Charles W. Jeglikowski, for the respondent.

Memorandum Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1972 in the amount of $26,205. The case is presently before the Court on cross-motions of the parties to dismiss for lack of jurisdiction. The notice of deficiency was mailed on May 29, 1981, and the petition was filed 91 days thereafter, on August 28, 1981. Respondent's motion requests dismissal on the ground that petitioners failed to file a...

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