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RACZKOWSKI v. COMMISSIONER

Dkt. No. 20557-06.

93 T.C.M. 1045 (2007)

T.C. Memo. 2007-72

Ronald S. Raczkowski v. Commissioner.

United States Tax Court.

March 29, 2007.

Attorney(s) appearing for the Case

Blake W. Ferguson and Ronald J. Goldstein, for respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge:

This case is before the Court on respondent's Motion To Dismiss For Lack Of Jurisdiction, filed November 17, 2006. Respondent moves to dismiss this case on the ground that the petition was not filed within the time prescribed by section 6213(a) or section 7502.1 As explained below, we shall grant respondent's motion to dismiss.

Background

Petitioner resided...

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