- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011