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PICKERING v. COMMISSIONER

Docket No. 19487-97.

75 T.C.M. 2152 (1998)

T.C. Memo. 1998-142

Richard L. Pickering v. Commissioner.

United States Tax Court.

Filed April 16, 1998.

Attorney(s) appearing for the Case

Richard L. Pickering, pro se. Richard Fultz, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1

This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction, filed November 25, 1997. There is no dispute that the petition was not filed within the 90-day period prescribed by section 6213(a). The question presented is whether the notice of...

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