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HERRERA v. COMMISSIONER

Docket No. 9565-83.

47 T.C.M. 985 (1984)

T.C. Memo. 1984-47

Efren and Suzanne Herrera v. Commissioner.

United States Tax Court.

Filed January 30, 1984.

Attorney(s) appearing for the Case

Donald L. Stuart, Herbert S. Kendrick, and Don C. Stephenson, 2800 Republic Bank, Dallas Bldg., Dallas, Tex., for the petitioners. Helen T. Repsis, for the respondent.

Memorandum Opinion

GOFFE, Judge:

This fully stipulated case is before us on respondent's motion to dismiss for lack of jurisdiction on the grounds that the petition in this proceeding was not filed within 90 days after the mailing of the notice of deficiency, as provided by section 6213(a).1

On January 21, 1983, the Commissioner timely mailed to petitioners, at their proper address, a statutory notice of deficiency. The...

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