Lawrence J. Polidori - Page 28

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          for such years.  Sec. 6501(c)(1).  Respondent, however, has not             
          established fraud against petitioner with respect to taxable                
          years 1985 or 1986.  Accordingly, because the notice of                     
          deficiency was issued on November 4, 1994, the periods of                   
          limitations for taxable years 1985 and 1986 have expired.  Sec.             
          6501(a).                                                                    
               To reflect the foregoing,                                              
                                             Decision will be                         
                                        entered under Rule 155.                       

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