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DHILLON v. COMMISSIONER

Docket No. 16971-98.

78 T.C.M. 1 (1999)

T.C. Memo. 1999-214

Bhupindar S. and Rajinder K. Dhillon v. Commissioner.

United States Tax Court.

Filed July 1, 1999.

Attorney(s) appearing for the Case

Craig M. Hunt, for the petitioners. LaVonne D. Lawson, for the respondent.

MEMORANDUM OPINION

NIMS, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction on the ground that petitioners did not file their petition within the time prescribed by section 6213(a). In reply to respondent's motion to dismiss, petitioners assert that the period for filing the petition under section 6213(a) is inapplicable. Instead, petitioners argue that their petition was timely filed pursuant to section 6226...

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