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WILLIAMS v. C.I.R.

No. 89-70527.

935 F.2d 1066 (1991)

Diane WILLIAMS, Petitioner-Appellant, v. COMMISSION INTERNAL REVENUE SERVICE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided June 11, 1991.

Attorney(s) appearing for the Case

Joseph F. Moore, Bigelow, Moore & Tyre, Pasadena, Cal., for petitioner-appellant.

John Dudeck, Gary R. Allen, Gilbert S. Rothenberg, and Janet Kay Jones, U.S. Dept. of Justice, Tax Div., Washington, D.C., for respondent-appellee.

Before GOODWIN, HUG, and FARRIS, Circuit Judges.

HUG, Circuit Judge:

Appellant Diane Williams ("Williams") appeals the Tax Court's dismissal of her petition for redetermination of a deficiency in income tax. The dismissal was based upon a finding by the Tax Court that the petition was untimely and, therefore, the Tax Court had not jurisdiction. We have jurisdiction pursuant to 26 U.S.C. § 7482.

There is no question but that the petition was not filed within the prescribed period from the date the notice...

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