United States Tax Court May 23, 1985, Docket No. 29871-82. (Dell v. Commissioner)

SAMUEL R. DELL and ELEANOR DELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Dell v. Commissioner Docket No. 29871-82. United States Tax Court T.C. Memo 1985-246; 1985 Tax Ct. Memo LEXIS 387; 49 T.C.M. (CCH) 1538; T.C.M. (RIA) 85246; May 23, 1985. *387 Held: Petitioners' Motion for Further Trial is denied as untimely.