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DAN v. COMMISSIONER

Docket No. 22262-96.

74 T.C.M. 1 (1997)

T.C. Memo. 1997-303

Gerry Dan and Kelly M. Langston v. Commissioner.

United States Tax Court.

Filed July 1, 1997.

Attorney(s) appearing for the Case

James D. Williams, Tulsa, Okla., for the petitioners. Ann L. Darnold, for the respondent.

MEMORANDUM OPINION

COUVILLION, Special Trial Judge:

Respondent filed a motion to dismiss this case for lack of jurisdiction on the ground that the petition was not timely filed. Petitioners, through counsel, filed a notice of objection. The motion was assigned for hearing pursuant to section 7443A(b)(4)1 and Rules 180, 181, and 183. The motion was calendared for hearing and was heard.

Respondent determined against petitioners...

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