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RAMIREZ v. COMMISSIONER

Docket No. 12373-85.

87 T.C. 643 (1986)

ALVARO RAMIREZ, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 23, 1986.

Attorney(s) appearing for the Case

Sidney A. Soltz, for the petitioner.

Susan Wynne, for the respondent.

GOFFE, Judge:

This case is before us on respondent's motion to dismiss for lack of jurisdiction based upon the petition's being filed more than 3 years after the mailing of the statutory notice of deficiency. We must now decide if a statutory notice of deficiency, mailed subsequent to a termination assessment by the Commissioner, but not within the specified period set forth in section 6851(b),1

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