Memorandum Opinion
WELLS, Judge:
The instant case is before us on respondent's motion to dismiss for lack of jurisdiction on the ground that petitioner failed to file her petition within the time prescribed by section 6213(a) or 7502. Unless otherwise indicated, all section references are to the Internal Revenue Code. A hearing was held on the instant motion. Petitioner did not appear at the hearing, nor did she file a statement under Rule 50(c). Respondent...
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