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SMITH v. COMMISSIONER

Docket No. 12605-08.

140 T.C. 48 (2013)

DEBORAH L. SMITH, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 28, 2013.

Attorney(s) appearing for the Case

William Edward Taggart, Jr., for petitioner.

Randall E. Heath and Thomas R. Mackinson, for respondent.

FOLEY, Judge:

The issue for decision is whether petitioner, pursuant to section 6213(a), had 90 or 150 days to file her petition with this Court.1

FINDINGS OF FACT

Petitioner and her husband untimely filed a joint Federal income tax return relating to 2000. Subsequently, the Internal Revenue Service selected petitioner and her husband's 2000 return for examination. On November 4, 2004, petitioner and her husband signed...

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