STEWART v. COMMISSIONER

Docket No. 1579-70.

55 T.C. 238 (1970)

FRANCES LOIS STEWART, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 29, 1970.


Attorney(s) appearing for the Case

Edward Sumner, for the petitioner.

Aleksandrs V. Laurins and Richard K. Seltzer, for the respondent.


DRENNEN, Judge:

Respondent filed a motion to dismiss the petition herein on the ground that the Court lacks jurisdiction because the petition was not timely filed. Petitioner filed an objection thereto and a hearing on the motion was held at which both parties introduced evidence in support of their positions. At the conclusion of the hearing both parties requested permission to file written memoranda and the Court took the motion under advisement.

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