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HAMMANN v. COMMISSIONER

Docket No. 15779-88.

57 T.C.M. 1045 (1989)

T.C. Memo. 1989-361

Hans H. and Cheryl E. Hammann v. Commissioner.

United States Tax Court.

Filed July 24, 1989.

Attorney(s) appearing for the Case

Richard E. Schneyer and Herta von Stiegel, for the petitioners. Terry W. Vincent and Dale Zusi, for the respondent.

Memorandum Findings of Fact and Opinion

PANUTHOS, Special Trial Judge:

This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction.1 Respondent seeks dismissal on the ground that the petition was not filed within the time prescribed by section 6213(a).

In his notice of deficiency dated October 6, 1987, respondent determined a deficiency in petitioners' Federal income tax for the taxable year...

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