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MALEKZAD v. COMMISSIONER

Docket No. 21285-80.

76 T.C. 963 (1981)

JAHANGIR MALEKZAD AND JILA MALEKZAD, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 9, 1981.

Attorney(s) appearing for the Case

William G. Morschauser, for the petitioners.

Michael C. Cohen, for the respondent.

OPINION

PARKER, Judge:

This matter comes before the Court on respondent's motion to dismiss for lack of jurisdiction on the ground that the petition was not timely filed within the 90-day period prescribed by sections 6213(a) and 7502.1 Petitioners contend that their petition was timely filed within the 90-day period under those sections. Alternatively, petitioners assert that...

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