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date upon which the decision was entered in the partnership
proceeding.
Respondent contends that the decision in the partnership
proceeding was entered on May 27, 1994, when this Court entered
the decision based on the stipulated settlement agreement.
Respondent contends further that this decision became final on
August 25, 1994, which is 90 days following entry of the
decision. Therefore, respondent argues, under section 6229(d),
the period of limitation was suspended until August 25, 1995,
which is 1 year from the date the decision became final. Since
the subject notices of deficiency were issued on May 19, 1995,
respondent argues that the deficiency notices were timely issued.
Petitioners contend that the decision in the partnership
proceeding was entered on October 6, 1993, the date this Court
granted respondent's motion to dismiss for lack of jurisdiction
with respect to the at-risk issue under section 465. Petitioners
argue further that this decision became final on January 4, 1994,
which is 90 days following the entry of such "decision".
Therefore, petitioners argue, under section 6229(d), the period
of limitation was suspended only until January 4, 1995, which is
1 year from the date the "decision" became final. Since the
relevant notices of deficiency were not issued until May 19,
1995, petitioners argue that the notices were not timely issued.
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