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became concerned that Wynne might carry out some threats she had
made against petitioner’s life. Ms. Mellerke’s concerns
ultimately came to the attention of the local police. At the
time of trial in this case, Wynne (now known as Wynne Superson)
was incarcerated in the Metropolitan Correctional Center in
Chicago, Illinois, awaiting sentencing after having been
convicted of a violation of 18 U.S.C. section 1958 (1994), use of
interstate commerce facilities in the commission of murder-for-
hire. The intended victim of her scheme was petitioner.
The notice of deficiency in this case was issued on May 3,
1994, and on July 28, 1994, petitioner timely filed a petition.
In September of 1995, petitioner filed an amended petition,
asserting for the first time that the period of limitations for
assessment of the taxes and addition to tax at issue had expired.
In supporting documents he maintained that he had not signed,
authorized, or ratified the consent to extend the period of
limitations relating to his 1980 taxable year.
Respondent’s counsel subsequently conducted a deposition of
Wynne with respect to the issues in this case, but she refused to
answer any questions, citing her privilege against self-
incrimination.
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