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LOYD v. COMMISSIONER

Docket No. 16885-82.

47 T.C.M. 1450 (1984)

T.C. Memo. 1984-172

Heywood R. Loyd and Jean C. Loyd v. Commissioner.

United States Tax Court.

Filed April 4, 1984.

Attorney(s) appearing for the Case

D. Derrell Davis, 200 Main Street, Litte Rock, Ark., for the petitioners. Val Albright, for the respondent.

Memorandum Findings of Fact and Opinion

FEATHERSTON, Judge:

Before the Court is respondent's motion to dismiss the case for lack of jurisdiction on the ground that the petition was not filed within 90 days of the date on which the notice of deficiency was mailed as required by section 6213(a).1 Also before the Court is petitioners' oral motion to dismiss the case for lack of jurisdiction on the ground that the notice of deficiency...

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