18 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18
Last modified: May 25, 2011