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MIANUS REALTY COMPANY, INC. v. COMMISSIONER

Docket Nos. 3137-67, 3199-67.

50 T.C. 418 (1968)

MIANUS REALTY COMPANY, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT McNEIL BROTHERS, INCORPORATED, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 4, 1968.

Attorney(s) appearing for the Case

Lawrence B. Schwartz, for the petitioners.

Andrew S. Coxe, for the respondent.

OPINION

DRENNEN, Judge:

These matters were before the Court on respondent's motions to dismiss the petitions for lack of jurisdiction on the grounds that the petitions were not timely filed, i.e., within 90 days after the notices of deficiency were mailed to petitioners. Petitioners objected on the grounds that petitioners had 150 days rather than the usual 90 days within which to file these petitions under section 6213(a), I.R.C. 1954.

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