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FINNELL v. COMMISSIONER

Docket No. 17870-97R.

75 T.C.M. 2225 (1998)

T.C. Memo. 1998-159

Glen A. Finnell v. Commissioner.

United States Tax Court.

Filed May 4, 1998.

Attorney(s) appearing for the Case

Glen A. Finnell, pro se. William I. Miller, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

Respondent moves the Court to dismiss this case for lack of jurisdiction, alleging that petitioner's petition for declaratory judgment was not filed within the time prescribed in section 7476(b)(5).1 Petitioner objects thereto. Petitioner alleges that a letter he wrote to the Internal Revenue Service should be considered his petition to this Court, and, if it is not, that equitable considerations...

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