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expiration of the 3-year period, in February 1985 petitioner and
respondent executed a Form 872-A, Special Consent to Extend the
Time to Assess Tax. The agreement extended the period of
limitations until the 90th day after (1) either party mailed to
the other a Form 872-T, Notice of Termination of Special Consent
to Extend the Time to Assess Tax, or (2) respondent issued a
notice of deficiency. Neither petitioner nor respondent executed
a Form 872-T prior to issuance of the notice of deficiency for
1981, which was dated October 5, 1989. Accordingly, the notice
of deficiency for taxable year 1981 was issued within the
statutory limitations period, as extended by agreement, and the
assessment for 1981 is not barred by the statute of limitations.
The deficiency in petitioners' 1979 Federal income tax is
attributable entirely to an unused credit carryback from 1982.
Therefore, the timeliness of the notice of deficiency for 1979 is
controlled by the limitations period for assessing the 1982
deficiency. Sec. 6501(j). Petitioner filed his return for
1982--from which the unused credit was carried back--on or about
April 15, 1983. Consequently, in the absence of any extension,
the 3-year period of limitations for 1982 would have expired on
April 15, 1986. Sec. 6501(a). Before such time, however, in
February 1986 petitioner and respondent executed a Form 872-A,
and indefinitely extended the limitations period under the same
terms agreed upon for 1981. Neither petitioner nor respondent
executed a Form 872-T prior to issuance of the notices of
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