VITALE v. COMMISSIONER

Docket No. 821-72.

59 T.C. 246 (1972)

ANGELO VITALE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 13, 1972.


Attorney(s) appearing for the Case

C. John Forge, for the petitioner.

James T. Finlen, for the respondent.


OPINION

TIETJENS, Judge:

The matter before us is the Commissioner's motion to dismiss on the ground that petitioner failed to file a timely petition with this Court. Evidence was taken at a hearing on the motion held in Kansas City, Mo., on June 6, 1972. The Commissioner determined deficiencies for 1967 and 1968 in the income tax liability of Angelo Vitale, a resident of Kansas City, Mo., in the amounts of

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