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to tax under sections 6653(a) and 6659. None of the trial
memoranda or briefs in docket No. 24512-89 address this issue.
Regardless of whether the issue was abandoned, the record in
docket No. 24512-89 shows that the notice of deficiency in that
case was issued within the statutory limitations period. In
general, section 6501(a) requires assessment of tax to be made
within 3 years after a return is filed, whether the return was
filed on or after the date prescribed. Section 6501(b)(1)
provides that if a return is filed before the due date, for
purposes of section 6501, the return shall be considered filed on
the due date. Section 6501(c)(4) provides that 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.
The Davids' joint 1982 Federal income tax return was due on
April 15, 1983, and was filed on or before that date. Therefore,
the 3-year period of limitations under section 6501(a) initially
was set to expire on April 15, 1986. However, the Davids and
respondent executed three consecutive Forms 872, Consent to
Extend the Time to Assess Tax. The first of these Forms 872 was
fully executed on March 21, 1986, prior to expiration of the
normal 3-year period of limitations, and the last of these Forms
872 extended the period of limitations to December 31, 1989. The
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