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SCHUSTER v. COMMISSIONER

Docket No. 32011-84.

51 T.C.M. 792 (1986)

T.C. Memo. 1986-134

Susie Schuster a/k/a Susie Schuster Translateur v. Commissioner.

United States Tax Court.

Filed April 3, 1986.

Attorney(s) appearing for the Case

Jorge Rodriguez-Chomat, 2153 Coral Way, Miami, Fla., for the petitioner. Irene Scott Carroll, for the respondent.

Memorandum Opinion

NIMS, Judge:

Respondent has moved for the dismissal of this case due to lack of jurisdiction premised upon the ground that the petition was not filed within 90 days of the mailing of the statutory notice of deficiency as required by section 6213(a).1 Petitioner admits that her petition was filed 454 days after the notice was mailed, but counters that respondent did not send the notice to petitioner's last known...

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