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POLO v. COMMISSIONER

Docket No. 27264-89.

61 T.C.M. 1689 (1991)

T.C. Memo. 1991-16

Roberto C. Polo v. Commissioner.

United States Tax Court.

Filed January 17, 1991.

Attorney(s) appearing for the Case

Michaell S. Fuerst, 19 W. Flagler St., Miami, Fla., for the petitioner. Scott P. Borsack and Anne Hintermeister, for the respondent.

Memorandum Opinion

POWELL, Special Trial Judge:1

This case is before the Court on respondent's Motion to Dismiss for Lack of Jurisdiction on the ground that the petition was not timely filed. The motion was submitted on a stipulated record. The essential facts are not in dispute and may be summarized as follows.

Petitioner allegedly headed several international investment funds during the early and mid-1980s. Prior to...

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