Memorandum Opinion
STERRETT, Judge:
This case is presently before the Court on respondent's motion to dismiss for lack of jurisdiction. The sole issue for our decision is whether the petition in the instant case should be considered timely filed pursuant to sections 6213 and 7502, I.R.C. 1954, even though it was received by this Court beyond the 90-day statutory period. A hearing on the motion was held in St. Paul, Minnesota on March 16, 1981. At the conclusion...
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