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based on self-assessment and serve "to ensure that passage of
time will not prevent collection of the tax unless the Government
has been informed by the taxpayer that there is, or might be, tax
liability". Lucia v. United States, 474 F.2d 565, 570 (5th Cir.
1973); see Bresson v. Commissioner, supra at 189 ("Federal
revenue law requires national application that is not displaced
by variations in State law").
Petitioner's post-hearing memorandum includes an alternative
allegation that the Texas statute of limitations is controlling
in this case on the ground that the validity of the disputed
power of attorney affects property rights and obligations between
petitioner and Ms. Cade. Petitioner fails to cite any direct
authority in support of this argument.
We are not persuaded that the disputed power of attorney
vested petitioner with any cognizable property rights. Notably,
the power of attorney did not expressly authorize petitioner to
make gifts on Ms. Cade's behalf, nor did it provide for the
transfer of ownership of any specific property to petitioner.
See Patch v. Commissioner, T.C. Memo. 1980-11. The power of
attorney, on its face, merely creates an agency relationship
between petitioner and Ms. Cade. See id.
Petitioner filed his tax returns for the years in issue on
October 18, 1995. Consistent with the preceding discussion, we
hold that respondent had 3 years from that date to issue a notice
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