Oliver K. Robinson and Deborah L. Robinson, et al. - Page 1

                                   117 T.C. No. 25                                    

                               UNITED STATES TAX COURT                                

                OLIVER K. ROBINSON AND DEBORAH L. ROBINSON, ET AL.,1                  
             Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent              

               Docket Nos. 4428-98, 4429-98,       Filed December 19, 2001.           

                           R determined that certain expenditures                     
                    made by P’s wholly owned subch. C corporation                     
                    (C) constituted constructive dividends to P.                      
                    At the time that R mailed a notice of                             
                    deficiency to P, the period for assessment of                     
                    1992 fiscal year tax with respect to C had                        
                    expired, whereas the period for assessment of                     
                    1992 tax for P had been extended and had not                      
                    expired.  Because the adjustment to P derives                     
                    from C’s transactions, P contends that C’s                        
                    period for assessment should govern R’s                           
                    ability to make a determination and/or assess                     
                    tax with respect to P or C.  Sec. 6501(a),                        

               1 The following cases have been consolidated for purposes of           
          trial, briefing, and opinion:  Pak West Airlines, Inc., docket              
          No. 4429-98; and Career Aviation Academy, Inc., docket No. 4435-            

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