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Because the period of limitations for 1985 under section
6501 expired before the notices of deficiency were issued in the
instant cases, assessment in each of the instant cases is barred
by the statute of limitations.
Petitioners ask us to also decide the following:
(1) Each of the final decisions entered pursuant to our
opinion in Steiner v. Commissioner, T.C. Memo. 1995-122, “Does
Not Represent a Determination described in Code section
1312(3)(B) for Purposes of the Mitigation Provisions.”
(2) “The Statute of Limitations for 1985 Expired [sic] on
April 15, 1989 [sic] prior to the issuance of the Notice of
Deficiency for 1984.”
Our conclusions in the instant cases, and the decisions
entered herein, would not be affected by any conclusion we might
state as to either of these issues. Accordingly, we decline to
analyze either of these issues. Chevron Corp. v. Commissioner,
98 T.C. 590 (1992); LTV Corp. v. Commissioner, 64 T.C. 589
(1975).
In light of the foregoing.
Respondent’s motions will be
granted, and decisions will be
entered that there are no
deficiencies and no additions
to tax.
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Last modified: May 25, 2011