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FOGDERUD v. COMMISSIONER

Docket No. 5197-98.

77 T.C.M. 1227 (1999)

T.C. Memo. 1999-13

David J. and Patricia A. Fogderud v. Commissioner.

United States Tax Court.

Filed January 25, 1999.

Attorney(s) appearing for the Case

Michael F. O'Donnell, for the respondent.

MEMORANDUM OPINION

PAJAK, Special Trial Judge:

This case comes before the Court on respondent's motion to dismiss for lack of jurisdiction on the ground that the petition was not filed within the time prescribed by sections 6213(a) or 7502. This case was heard pursuant to section 7443A(b)(3) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code for the years in issue. All Rule references are to the Tax Court Rules of Practice...

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