- 13 -
1985 and under section 6653(b)(1)(A) and (B) for 1986 and 1987.
On the same date, respondent issued a separate notice to pe-
titioner for 1988 through 1990. Respondent determined in that
notice that petitioner is liable for the additions to tax for
fraud under section 6653(b)(1) for 1988 and the additions to tax
for fraudulent failure to file under section 6651(f) for 1989 and
1990.
OPINION
In the portion of her brief headed "POINTS RELIED UPON",
petitioner asserts:
There was no fraud committed by petitioner; there-
fore, she is not liable for any penalty under IRC ��
6651(f), 6653(b)(1), 6653(b)(1)(A), 6653(b)(1)(B) or
6653(b)(2).
No other penalties can be assessed against pe-
titioner, because the statute of limitations for as-
sessment and collection of a tax liability for the
taxable years ended December 31, 1986,[3] through 1990,
expired prior to respondent's issuance of the statutory
notices of deficiency. More specifically, petitioner
filed her income tax returns for the period in question
in May 1992. The Commissioner issued statutory notices
of deficiency on April 18, 1997. Petitioner did not
execute any type of document extending the statute of
limitations prior to the date of expiration of the
assessment period. The three-year period for assess-
ment expired prior to April 18, 1997. The six-year
period for assessment does not apply because the IRS
[sic] the income and deductions reported on peti-
tioner's returns was accepted as correct after examina-
tion by the IRS. [Fn. added]
3Although not altogether clear, we presume that the refer-
ence to the taxable year ended Dec. 31, 1986, is a typographical
error. We shall proceed on the assumption that petitioner claims
that the period of limitations for 1985 also has expired.
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