United States Tax Court June 9, 1981, Docket No. 21285-80 (Malekzad v. Commissioner)

OPINION

Parker, Judge:

This matter comes before the Court on respondent’s motion to dismiss for lack of jurisdiction on the ground that the petition was not timely filed within the 90-day period prescribed by sections 6213(a) and 7502.1 Petitioners contend that their petition was timely filed within the 90-day period under those sections.