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FILEFF v. COMMISSIONER

Docket No. 28373-89.

60 T.C.M. 582 (1990)

T.C. Memo. 1990-452

Anastas and Nancy A. Fileff v. Commissioner.

United States Tax Court.

Filed August 22, 1990.

Attorney(s) appearing for the Case

Robert A. Stevenson, 12760 S. Harlem Ave., Palos Heights, Ill., for the petitioners. James C. Lanning, for the respondent.

Memorandum Findings of Fact and Opinion

HAMBLEN, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction on the ground that the petition was not timely filed. The issues to be decided are (1) whether respondent's notice of deficiency is valid and, if so, (2) whether the petition was timely filed.

An evidentiary hearing was held on respondent's motion in Chicago, Illinois. Based on the Court's record and the...

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