Estate of Donald H. Ray, Deceased, Patricia G. Ray, Independent Executrix, and Patricia G. Ray - Page 18

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          record, we find that the parties entered into the settlement                
          agreement on December 6, 1991, when respondent's authorized                 
          representative executed the Form 870-L(AD).  As such, we conclude           
          that the notices of deficiency issued on December 4, 1992, were             
          issued prior to the expiration of the applicable period of                  
          limitations.                                                                
               To reflect the foregoing and the concessions by the parties,           
                                                  Decisions will be entered           
                                             under Rule 155.                          































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