United States Tax Court, 1997

Langston v. Commissioner

United States Tax Court · Decided July 1, 1997

1997 T.C. Memo. 303; 74 T.C.M. 1; 1997 Tax Ct. Memo LEXIS 369

Opinion

GERRY DAN AND KELLY M. LANGSTON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 22262-96

United States Tax Court

T.C. Memo 1997-303; 1997 Tax Ct. Memo LEXIS 369; 74 T.C.M. (CCH) 1;

July 1, 1997, Filed

James D. Williams, for petitioners.

Ann L. Darnold, for respondent.

COUVILLION

MEMORANDUM OPINION

COUVILLION, Special Trial Judge: Respondent filed a motion to dismiss this case for lack of jurisdiction on the ground that the petition was not timely filed. Petitioners, through counsel, filed a notice of objection. The motion was assigned for hearing pursuant to section 7443A(b)(4) ¹ and Rules 180, 181, and 183. The motion was calendared for hearing and was heard.

*370 Respondent determined against petitioners the following deficiencies in Federal i

Footnotes

1. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years at issue. All Rule references are to the Tax Court Rules of Practice and Procedure.↩

Case-law data current through December 31, 2025. Source: CourtListener bulk data.