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ZENCO ENGINEERING CORP. v. COMMISSIONER

Docket No. 4692-80.

75 T.C. 318 (1980)

ZENCO ENGINEERING CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 1, 1980.

Attorney(s) appearing for the Case

William J. Wise, for the petitioner.

Tommy F. Thompson, for the respondent.

OPINION

FAY, Judge:

This case comes before us on respondent's motion to dismiss for lack of jurisdiction on the ground the petition was not filed within the statutory 90-day period, and on petitioner's motion to dismiss for lack of jurisdiction on the ground the notice of deficiency was not properly mailed and delivered.

The following facts are uncontroverted:

After an audit and petitioner's administrative appeals, respondent on June...

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