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GUERRA v. COMMISSIONER

Docket No. 3194-82.

45 T.C.M. 510 (1983)

T.C. Memo. 1983-21

Hector Guerra and Elsa Guerra v. Commissioner.

United States Tax Court.

Filed January 13, 1983.

Attorney(s) appearing for the Case

Kenton E. McDonald and James L. Walker, 1700 First City Bk., Corpus Christi, Tex., for the petitioners. Dennis R. Onnen, for the respondent.

Memorandum Opinion

WILES, Judge:

This case is before us on respondent's "Motion to Dismiss for Lack of Jurisdiction" filed on March 22, 1982, and heard on August 16, 1982. Respondent, who determined that petitioners are liable for additions to tax1 under section 6653(b) in the amounts of $8,197.89 for 1976 and $6,526.46 for 1977, contends that the petition herein was not filed within the period prescribed in sections 6213(a)...

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