Benjamin and Sallie Campfield - Page 3

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               (3) Whether the assessments for 1984, 1985, and 1986 are               
          barred by the statute of limitations.  We hold that the                     
          assessments are not barred.                                                 
               All section references are to the Internal Revenue Code in             
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure, unless otherwise                 
          indicated.                                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts are stipulated and are so found.  We                 
          incorporate by reference the stipulation of facts and attached              
          exhibits.                                                                   
               Benjamin and Sallie Campfield (petitioners) are husband and            
          wife, and they resided in Trumbull, Connecticut, at the time they           
          filed their petition.  Benjamin Campfield (petitioner) was born             
          in Sylvania, Georgia.  His education did not proceed beyond the             
          seventh grade.                                                              
          Arturo's, Inc.                                                              
               From 1969 through 1988, petitioner was the sole shareholder            
          of Arturo's, Inc. (Arturo's), which operated a cafe and bar under           
          the name "Club 1127" in Bridgeport, Connecticut.  Arturo's was              
          predominantly a cash business during the years 1984 through 1986.           
          Arturo's filed U.S. Corporation Income Tax Returns (Forms 1120)             
          for the fiscal years ended May 31, 1982, through 1986.                      








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