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EWING v. COMMISSIONER

Docket No. 1940-01.

118 T.C. 494 (2002)

118 T.C. No. 31

GWENDOLYN A. EWING, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 31, 2002.

Attorney(s) appearing for the Case

Karen L. Hawkins, for petitioner.

Thomas M. Rohall, for respondent.

OPINION

RUWE, Judge:

This case is before the Court on respondent's motion to dismiss for lack of jurisdiction. Respondent's motion is based on the ground that the petition was not timely filed. We held a hearing on respondent's motion during which we raised sua sponte the issue of whether we lack jurisdiction under section 6015(e)1 to review respondent's denial of equitable relief pursuant to section 6015(f) where no deficiency...

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