- 32 - he attached to the return for that year a disclosure statement asserting that the return was substantially incomplete, because at the time of filing he had not received from Mr. Feltman information needed to prepare the return. On audit, respondent determined that petitioners had unreported income for 1984, 1985, and 1986 of $1,540,000, $1,365,462, and $1,642,537, respectively. Additionally, respondent determined that Mr. Gherman had unreported income for 1987 and 1988 of $1,529,500 and $1,645,000, respectively. The notices of deficiency for the years in issue were mailed on July 19, 1991, and state that respondent's determinations were "based on information available from certificates of deposit records compiled by the bankruptcy trustee." OPINION Statutory Period of Limitations Petitioners contend that assessment of the deficiency and additions to tax that respondent determined for each of the years ended 1984 through 1988 is barred by expiration of the periods of limitations under section 6501. Respondent contends, however, that the period of limitations to assess the deficiencies and additions to tax has not expired for any year in issue. Generally, under section 6501(a) an income tax deficiency and additions to tax must be assessed within 3 years of the later of (1) the date the tax return was filed or (2) the due date ofPage: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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