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WOOD v. COMMISSIONER

Docket No. 3030-63.

41 T.C. 593 (1964)

C. LOUIS WOOD AND HALLIE D. WOOD, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 29, 1964.

Attorney(s) appearing for the Case

Jack D. Swaner, for the petitioners.

Roger A. Pott, for the respondent.

DRENNEN, Judge:

Involved here is respondent's motion to dismiss this case for lack of jurisdiction because of the failure of petitioners to file a petition within the period prescribed by the applicable provisions of the Internal Revenue Code of 1954. Petitioners opposed the motion and a hearing on the motion was held at San Francisco, Calif., on November 7, 1963, at which time petitioners offered evidence in support of their position.1

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