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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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