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PHILLIPS v. COMMISSIONER

Docket No. 4706-94.

71 T.C.M. 2850 (1996)

T.C. Memo. 1996-196

Charles T. and Joan B. Phillips v. Commissioner.

United States Tax Court.

Filed April 23, 1996.

Attorney(s) appearing for the Case

Thomas E. Redding, Houston, Tex., and Sallie W. Gladney, for the petitioners. John F. Eiman and Thomas Fenner, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

FAY, Judge:

This case is before the Court on the parties' cross-motions to dismiss for lack of jurisdiction. The parties have stipulated that petitioners1 filed a petition with the U.S. Tax Court on March 21, 1994, more than 90 days after both notices of deficiency were mailed. On May 20, 1994, respondent filed a motion to dismiss for lack of jurisdiction on the ground that petitioners...

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