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FRAZELL v. COMMISSIONER

Docket No. 41891-86.

88 T.C. 1405 (1987)

GENE M. FRAZELL AND ALICE M. FRAZELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 27, 1987.

Attorney(s) appearing for the Case

Michael A. Shea and Miki Okumura, for the petitioners.

Carol K. Muranaka and Margaret A. Martin, for the respondent.

WILLIAMS, Judge:*

This case is before us on respondent's motion to dismiss for lack of jurisdiction on the ground that the petition was not timely filed pursuant to section 6213(a) and on petitioners' cross-motion to dismiss for lack of jurisdiction on the ground that the notice of deficiency is invalid because respondent failed to comply with the partnership audit and litigation procedures, section 6221 et seq.

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