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Petitioners rely upon Elizalde v. Commissioner, T.C. Memo.
1984-243, a case that is distinguishable. In the first place,
the transferee prevailed there on the ground that she was not
liable as a transferee wholly apart from any issue relating to
limitations. Second, even in respect of limitations the Court's
analysis of the problem did not take into account what we regard
as the controlling final parenthetical "in any event" clause in
section 6503(a)(1), posing a serious question whether the point
was ever properly presented to the Court by the parties.
Moreover, the Court ultimately held that the period of
limitations had not expired, and it was therefore not necessary
in that case to consider whether the period of limitations was
extended for 90 days after the entry of the stipulated decision
prior to the addition of the 60 days, as we have done here--a
matter that is of critical significance in this case. Finally,
Elizalde was distinguished in a well-reasoned opinion by Judge
Friedman of the Federal Circuit in Pesko v. United States, 918
F.2d at 1583-1584. We do not find it necessary to comment
further on Elizalde.
Petitioners make other arguments concerning the expiration
date of the limitations period. They focus on the consent
agreement, which provides in pertinent part:
(1) The amount of any Federal Gift (Form 709) tax
due on any return(s) made by or for the above
taxpayer(s) for the period(s) ended December 31, 1983
may be assessed at any time on or before April 18,
1990. However, if a notice of deficiency in tax for
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