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PATMON AND YOUNG PROFESSIONAL CORP. v. C.I.R.

No. 93-1956.

55 F.3d 216 (1995)

PATMON AND YOUNG PROFESSIONAL CORPORATION, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided May 23, 1995.

Attorney(s) appearing for the Case

Clarence B. Tucker, Sr. (argued and briefed) and Frederick A. Patmon, Detroit, MI, for petitioner-appellant.

David L. Jordan, I.R.S., Office of Chief Counsel, Richard Farber, Sara K. Knutson (argued), and Gary R. Allen, Acting Chief (briefed), U.S. Dept. of Justice, Appellate Section Tax Div., Washington, DC, for respondent-appellee.

Before: WELLFORD, BOGGS, and SILER, Circuit Judges.

SILER, Circuit Judge.

Patmon and Young Professional Corporation ("P & Y") appeals the United States Tax Court's order dismissing its petition seeking redetermination of tax deficiencies assessed against P & Y. For the reasons stated herein, we hold that the Tax Court did not err in dismissing P & Y's petition for redetermination based upon lack of jurisdiction on the ground that it was untimely filed.

I.

On March 3, 1989, the Internal...

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