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FILOSA v. COMMISSIONER

Docket No. 19074-92.

66 T.C.M. 1705 (1993)

T.C. Memo. 1993-615

Alexander P. Filosa v. Commissioner.

United States Tax Court.

Filed December 22, 1993.

Attorney(s) appearing for the Case

Alexander P. Filosa, pro se.

Lewis J. Abrahams and Amy E. Gross (specially recognized), for the respondent.

Memorandum Opinion

POWELL, Special Trial Judge.

This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 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 within the meaning of sections 6213(a) and 7502.

The facts may be summarized as follows. On May 22, 1989, Alexander P. and Loretta...

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