PUGSLEY v. C.I.R.

Nos. 84-8316, 84-8318 Non-Argument Calendar.

749 F.2d 691 (1985)

Henry G. PUGSLEY, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. Joseph T. REZZONICO, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Eleventh Circuit.

Rehearing and Rehearing Denied February 26, 1985.


Attorney(s) appearing for the Case

Scott McLarty, Athens, Ga., for petitioners-appellants.

Michael Paup, Glenn L. Archer, Jr., Asst. Atty. Gen., Gilbert S. Rothenberg, Nancy Morgan, U.S. Dept. of Justice, Tax Div., Fred T. Goldberg, Chief Counsel, I.R.S., Robert B. Miscavich, Sr. Technician Reviewer, Washington, D.C., for respondent-appellee.

Before TJOFLAT, HILL and ANDERSON, Circuit Judges.


Rehearing and Rehearing En Banc Denied February 26, 1985.

PER CURIAM:

These two appeals arise from the tax court's dismissal of the taxpayers' petitions for redetermination of income tax deficiencies. We affirm the dismissals for lack of jurisdiction because the petitions were filed after the expiration of the 90-day period permitted for filing such petitions.

The facts in each case are undisputed. On October 4, 1983, the Commissioner of Internal Revenue...

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