Michael J. Seely & Nancy B. Seely v. Commissioner

T.C. Memo. 2020-6

UNITED STATES TAX COURT MICHAEL J. SEELY AND NANCY B. SEELY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15349-17. Filed January 13, 2020. Scott G. Boyce, for petitioners. Patsy A. Clarke and Melissa D. Lang, for respondent. MEMORANDUM OPINION VASQUEZ, Judge: This matter is before us on respondent’s motion to dismiss for lack of jurisdiction on the ground that the petition was not filed within -2- [*2] the time prescribed by section 6213(a) or section 7502.1 As explained below, we will deny respondent’s motion. Background The following facts are…