BURNSIDE v. COMMISSIONER

Docket No. 8305-98.

77 T.C.M. 1568 (1999)

T.C. Memo. 1999-85

Rosie Burnside v. Commissioner.

United States Tax Court.

Filed March 23, 1999.


Attorney(s) appearing for the Case

Rosie Burnside, pro se. Peter C. Rock and Paul R. Zamolo, for the respondent.


MEMORANDUM OPINION

VASQUEZ, Judge:

This matter is before the Court on respondent's motion to dismiss for lack of jurisdiction. The issue presented is whether petitioner had 90 or 150 days within which to file her petition to this Court under section 6213(a).1

Background

On January 28, 1998, petitioner left the United States for Nassau, Bahamas. On January 30, 1998, respondent mailed the statutory notice...

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