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CALVERT ANESTHESIA ASSOCIATES v. COMMISSIONER

Docket No. 18857-97R.

75 T.C.M. 2176 (1998)

T.C. Memo. 1998-149

Calvert Anesthesia Associates-Pricha Phattiyakul, M.D. P.A. v. Commissioner.

United States Tax Court.

Filed April 27, 1998.

Attorney(s) appearing for the Case

Mark C. Kopec, Paul W. Madden, and Herman B. Rosenthal, Baltimore, Md., for the petitioner. Clare J. Brooks, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

Respondent moves the Court to dismiss this case for lack of jurisdiction, alleging that petitioner's petition for declaratory judgment was not filed within the time prescribed in section 7476.1 Petitioner objects thereto. Petitioner alleges that the petition was timely, and, even if it was not, that respondent has waived the right to challenge the timeliness of the petition, or, alternatively,...

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