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and penalties for each of the years in issue is time barred
because respondent failed to issue the notice of deficiency
within the 3-year period prescribed by section 6501(a).
As we found herein, petitioner is liable for the additions
to tax for fraud for 1980, 1981, and 1982; therefore, the period
of limitations on assessment for those years remains open.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011