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SIMPSON v. COMMISSIONER

Docket No. 3215-81.

43 T.C.M. 282 (1982)

T.C. Memo. 1982-13

Samuel L. and Ima Jean Simpson v. Commissioner.

United States Tax Court.

Filed January 12, 1982.

Attorney(s) appearing for the Case

Samuel L. Simpson, pro se. Richard A. Witkowski, for the respondent.

Memorandum 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 sections 6213(a) and 7502(a).1 Respondent's motion was filed on March 24, 1981; petitioners' objections thereto were filed on May 4, 1981; and the motion was heard in Detroit, Michigan on October 26, 1981.

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