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In Roschuni v. Commissioner, 44 T.C. 80 (1965), the
taxpayer-wife owned an S corporation, which filed an information
return for 1958, a year for which the Commissioner determined a
deficiency against the taxpayers. The notice of deficiency was
issued more than 3 years, but less than 6 years, after
petitioners filed their 1958 tax return. We quoted extensively
from our opinion in Rose v. Commissioner, supra, concluded that
the S corporation was not a taxable entity, and stated that the
principle of Rose v. Commissioner applied. See Roschuni v.
Commissioner, 44 T.C. at 85-86. We described this principle as
requiring the information return of the nontaxable entity to be
treated as an adjunct of the taxpayers’ tax return. See id. at
85-86. We also held that the taxpayers’ reference, in their 1958
tax return, to the S corporation’s 1958 information return and
the disputed transaction, was sufficient to satisfy the
requirements of section 6501(e)(1)(A)(ii), and so any omitted
gross income from that transaction was not to be taken into
account. See id. at 85-86.
In Davenport v. Commissioner, 48 T.C. 921 (1967), the
taxpayers’ 1958, 1959, and 1960 tax returns reported losses from
a specified partnership. See id. at 924-925. The taxpayer-wife
contended that assessment of any deficiencies for these 3 years
was barred by the statute of limitations; the Commissioner
contended that the 6-year limitations period applied. See id. at
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