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notices of deficiency herein was issued after expiration of the
respective statutory limitations periods.8 Petitioners have the
burden of proving when the respective returns were filed and when
the general 3-year periods of limitations expired. Miami
Purchasing Service Corp. v. Commissioner, 76 T.C. 818, 823
(1981). Respondent bears the burden of proving that any
extensions of the periods of limitations are applicable. Id.
Section 6501(a) generally requires an assessment of tax to
be made within 3 years after a return is filed. In the case of a
deficiency attributable to a credit carryback, such deficiency
may be assessed at any time before the expiration of the period
within which a deficiency for the taxable year of the unused
credit that results in such carryback may be assessed. Sec.
6501(j). If, before the expiration of the time to assess the tax
under section 6501(a), the parties consent in writing to extend
the time for the assessment of the tax, the tax may be assessed
at any time before the end of the period agreed upon. Sec.
6501(c)(4).
Petitioner filed his 1981 Federal income tax return on or
about April 15, 1982. Therefore, in the absence of any
extension, the 3-year period of limitations for that year would
have expired on April 15, 1985. Sec. 6501(a). Prior to
8 In their posttrial briefs, the parties addressed this issue
only with respect to the notice of deficiency for 1979 and
petitioner Brenda Becker.
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