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relating to the year ended 1988 was mailed within 3 years of the
time in which the return for that year was filed. The 3-year
period of limitations for assessing the tax and additions to tax,
consequently, did not expire for the year ended 1988 before
respondent mailed the notice of deficiency relating to that year.
Accordingly, the statute of limitations does not bar respondent
from assessing any deficiencies in tax and additions to tax for
the year ended 1988.
Respondent does not deny that the notices of deficiency for
the years ended 1984 through 1987 were mailed more than 3 years
after the later of the date on which the returns were filed or
their due dates. Respondent contends, however, that petitioners
had unreported income in the amounts of $1,540,000, $1,365,462,
$1,642,537, and $1,529,500 for tax years ended 1984, 1985, 1986,
and 1987, respectively. Respondent further contends that the
unreported income exceeds 25 percent of the gross income of
$477,197, $498,634, $533,901, and $416,333 reported in the
returns for those years. Accordingly, respondent maintains, the
periods of limitations for assessment of any deficiencies for
1984 through 1987 had not expired when the notices of deficiency
were mailed because the 6-year period of limitations for the
assessment of tax applies for those years.
Whether respondent is barred from assessing additional tax
and additions to tax for the years ended 1984 through 1987 rests
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