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BOOTHE v. COMMISSIONER

Docket No. 33208-84.

52 T.C.M. 135 (1986)

T.C. Memo. 1986-361

Powers and Pamela Boothe v. Commissioner.

United States Tax Court.

Filed August 7, 1986.

Attorney(s) appearing for the Case

Glenn Guritzky and Robert E. Linkin, for the petitioners. Frances Ferrito Regan, for the respondent.

Memorandum Findings of Fact and Opinion

GERBER, Judge:

Respondent determined deficiencies in Federal income tax for petitioners' taxable years 1977 and 1980 in the amounts of $3,610 and $40,999, respectively. This proceeding arises from cross-motions to dismiss for lack of jurisdiction. Respondent's motion is based upon the contention that the petition was untimely. Petitioners' motion is based upon the contention that respondent did not send a statutory...

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