MEMORANDUM OPINION
RUWE, Judge:
This matter is before us on respondent's motion to dismiss for lack of jurisdiction on the grounds that the petition in this case was not filed within the time prescribed by section 6213(a).
During the 1982 taxable year, petitioner Jesus V. Cutillar was a partner in the partnership of Waltbar & Associates (Waltbar). Waltbar invested in two other partnerships, Whitman Recycling Associates...
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