LEVY v. COMMISSIONER

Docket No. 13824-79.

76 T.C. 228 (1981)

LEON M. LEVY AND CATHERINE J. LEVY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 12, 1981.


Attorney(s) appearing for the Case

Steven D. Lustig, for the petitioners.

Bryan R. Sullivan, for the respondent.


OPINION

WILBUR, Judge:

This matter comes before the Court on respondent's motion to dismiss for lack of jurisdiction. Petitioners objected to the motion, and the parties submitted a stipulation of facts, which is incorporated herein by this reference, and written briefs stating their positions.

We are called upon by respondent's motion and petitioners' objection to decide whether the petitioners herein were entitled to 150 days rather than...

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