BAILEY v. COMMISSIONER

Docket No. 8182-86.

53 T.C.M. 1447 (1987)

T.C. Memo. 1987-368

George S. Bailey III v. Commissioner.

United States Tax Court.

Filed July 27, 1987.


Attorney(s) appearing for the Case

Burgess J. W. Raby and Arthur P. Allsworth, for the petitioner. Anne W. Durning, for the respondent.


Memorandum Opinion

GERBER, Judge:

Respondent, by a Motion To Dismiss For Lack of Jurisdiction filed July 10, 1986, seeks the dismissal of this case because the petition was not filed within ninety days of the mailing of the statutory notices of deficiency. Petitioner objects to respondent's motion on the ground that the notices, although properly mailed, were allegedly mishandled and not delivered by the Postal Service. The specific issue presented is whether...

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