Memorandum Opinion
WELLS, Judge:
This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent seeks a dismissal on the ground that the petition was not filed within the time prescribed by sections 6213(a) and 7502. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue.
By Order of the Court petitioner was directed to file his objection, if any...
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