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As provided by section 7481(a)(1),3 a decision of the Tax
Court becomes "final" when the period for appeal expires without
the filing of an appeal. And, pursuant to section 7483, the
period for appeal ends 90 days after a decision is entered in the
Tax Court. Moreover, it has been uniformly held in a number of
cases where the issue has been analyzed that the 90-day period is
applicable even in the case of a stipulated decision. Pesko v.
United States, 918 F.2d 1581 (Fed. Cir. 1990); Sherry Frontenac,
Inc. v. United States, 868 F.2d 420 (11th Cir. 1989); Security
Indus. Ins. Co. v. United States, 830 F.2d 581 (5th Cir. 1987);
Lansburgh v. United States, 699 F. Supp. 279 (S.D. Fla. 1988);
Becker Bros., Inc. v. United States, 61 AFTR 2d 88-1147, 88-1
USTC par. 9262 (C.D. Ill. 1988).
Accordingly, since the decision in the donor's case was
entered February 25, 1992, it became final 90 days thereafter.
And, pursuant to section 6503(a)(1), the running of the section
6501 period of limitations was further suspended for that 90 days
plus 60 days after the 90 days, or a total of 150 days from
February 25, 1992, the day that the stipulated decision was
3 Sec. 7481(a)(1) provides:
(a) Reviewable Decisions.--Except as provided in
subsections (b), (c), and (d), the decision of the Tax
Court shall become final--
(1) Timely notice of appeal not filed.--Upon
the expiration of the time allowed for filing a
notice of appeal, if no such notice has been duly
filed within such time; * * *
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