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MADSEN v. COMMISSIONER

Docket No. 34102-87.

55 T.C.M. 704 (1988)

T.C. Memo. 1988-179

Raymond J. Madsen and Rene J. Madsen v. Commissioner.

United States Tax Court.

Filed April 28, 1988.

Attorney(s) appearing for the Case

Richard J. Albrecht, 4041 MacArthur Blvd., Newport Beach, Calif., for the petitioners. Jeffrey A. Hatfield, for the respondent.

Memorandum Opinion

SWIFT, Judge:

This matter is before the Court on respondent's amended motion to dismiss for lack of jurisdiction and to close the case on grounds of duplication. The primary issue is whether petitioners timely filed their petition in this case in accordance with section 6213(a).1

Petitioners resided in Santa Ana, California, when their petition was filed....

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