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BLANK v. COMMISSIONER

Docket No. 13566-80.

76 T.C. 400 (1981)

MERVYN BLANK AND JUNE BLANK, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 26, 1981.

Attorney(s) appearing for the Case

Donald L. Lawrence, for the petitioners.

Alan B. Horn, for the respondent.

OPINION

PARKER, Judge:

This matter is 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 section 6213(a).1 Petitioners filed a written objection to the motion and an evidentiary hearing was subsequently held at New York, N.Y. In opposition to respondent's motion, petitioners primarily argue that placing...

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