T.C. Memo. 1999-67 UNITED STATES TAX COURT UNILEVER SUPERANNUATION TRUSTEES LIMITED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10022-97. Filed March 5, 1999. K. Peter Schmidt, for petitioner. Gary D. Kallevang, for respondent. MEMORANDUM OPINION LARO, Judge: Petitioner moves for summary judgment, asserting that section 6501 does not allow respondent to assess tax for the years in issue. Respondent moves for partial summary judgment, asserting primarily that the notices of deficiency are timely under section 6501(c)(3). Respondent issued the noticesPage: 1 2 3 4 5 Next
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