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GRAY v. COMMISSIONER

Docket No. 27849-09L.

140 T.C. 163 (2013)

CAROL DIANE GRAY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 25, 2013.

Attorney(s) appearing for the Case

Jonathan P. Decatorsmith , for petitioner.

John Spencer Hitt , for respondent.

SUPPLEMENTAL OPINION

GALE, Judge:

In an Opinion previously issued in this case, Gray v. Commissioner, 138 T.C. 295 (2012), we held that we lacked jurisdiction to review respondent's determination to proceed with certain collection actions set forth in a notice of determination issued to petitioner (notice of determination) because the petition was untimely, not having been filed within 30 days of the notice of...

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