T.C. Memo. 1997-140 UNITED STATES TAX COURT ESTATE OF JAMES A. BEATON, DECEASED, SHIRLEY BEATON, EXECUTRIX, AND SHIRLEY BEATON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent ALAN B. STEINER AND BARBARA W. STEINER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 28181-92, 28182-92. Filed March 18, 1997. R issued notices of deficiency dated Sept. 28, 1992, for Ps’ 1985 year. Ps filed timely petitions asserting the period of limitations had expired. R filed answers asserting the application of the mitigation provisions. Secs. 1311-1314, I.R.C. 1986. Decisions as to 1984, entered pursuant to our opinion in Steiner v. Commissioner, T.C. Memo. 1995-122, which respondent contends are the relevant determinations, became final in late 1996. Held: The mitigation provisions do not permit an adjustment to Ps’ 1985 year, because on the date the notices of deficiency for 1985 were issued a relevant determination had not occurred within the 1-year period ending on that date.Page: 1 2 3 4 5 6 7 8 9 10 11 12 Next
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