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(docket No. 42224-85).
Pursuant to section 6503(a)(1) and section 301.6503(a)-1,
Proced. & Admin. Regs., the period of limitations on assessment and
collection of a deficiency is suspended for 90 days after a notice
of deficiency is mailed. Once a proceeding regarding the
deficiency is placed on the Tax Court docket, the period of
limitations is further suspended until the Tax Court decision
becomes final, and for an additional 60 days thereafter.
The August 26, 1985, notice of deficiency mailed to the estate
immediately suspended the period of limitations for assessment,
leaving 26 days on the statute. Docket No. 42224-85 remained on
the Tax Court docket until September 6, 1996, when this Court
entered its decision in the case. The decision became final 90
days thereafter; namely, December 6, 1996; it was not appealed.
See secs. 7481, 7483. As a consequence of these actions, the
period of limitations in docket No. 42224-85 was suspended from
August 26, 1985 (the date the notice of deficiency was mailed to
the estate), until December 6, 1996 (the date the decision became
final), plus an additional 60 days thereafter, or February 4, 1997.
See secs. 7481, 7483. Thus, the 26 days that remained on the
period of limitations for assessment after the notice was mailed is
tacked on to the suspension period with respect to the filing of a
petition in this Court (February 4, 1997), resulting in March 2,
1997, being the expiration date of the period of limitations for
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