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JAMES v. COMMISSIONER

Docket No. 28013-88.

59 T.C.M. 83 (1990)

T.C. Memo. 1990-128

James M. James v. Commissioner.

United States Tax Court.

Filed March 13, 1990.

Attorney(s) appearing for the Case

James M. James, pro se. Sarah Barkley, for the respondent.

Memorandum Opinion

PATE, Special Trial Judge:

This case is before the Court on cross motions to dismiss for lack of jurisdiction. Respondent maintains that the petition must be dismissed because petitioner did not file it within 90 days after the mailing of the notices of deficiency for 1984 and 1985, as required by section 6213(a).1 Petitioner contends that, because respondent did not mail the notices of deficiency to his "last...

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