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entered. Also, at the time of the issuance of the deficiency
notice (February 9, 1990), there remained unexpired 68 days of
the section 6501 period of limitations, which had been extended
to April 18, 1990. That remaining period of 68 days was
suspended by the issuance of the deficiency notice, and should
therefore be further added to the 150-day suspension provided by
section 6503(a)(1), for a total of 218 days. Such addition of
the unexpired 68 days to the period of suspension is firmly
supported by established law. It has long been held that it is
appropriate to add or "tack on" the days remaining when the
limitations period was interrupted or suspended by the issuance
of a deficiency notice. McClamma v. Commissioner, 76 T.C. 754,
758 (1981); see also Bales v. Commissioner, 22 T.C. 355, 359
(1954) (quoting Olds & Whipple v. United States, 86 Ct. Cl. 705,
22 F. Supp. 809, 819 (1938) (interpreting section 277(b) of the
1926 Revenue Act, the predecessor of section 6503(a)(1): "We
think the language of the statute is not reasonably susceptible
to any other construction. It plainly states that the running of
the statute of limitation shall be suspended and this can only
mean that when the period of suspension ceases the limitation
period again commences to run.")).
With the addition of the 68 days to the 150 days, the
limitations period for assessment against the donor expired no
earlier than October 1, 1992. Since, pursuant to section
6901(c), the limitations period for assessment of the transferees
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