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I.R.C., provides the general rule that R has
3 years after the “return” was filed to
assess. R contends that the “return”
referenced in sec. 6501(a), I.R.C., is the
return of the taxpayer for whom the
adjustment is being made. Conversely, P
contends that the “return” is that of the
entity from which the adjustment derives.
Held: In the factual context of this
case, the return referenced in sec. 6501(a),
I.R.C., is the return of the taxpayer for
whom the adjustment is determined and not the
return of the entity from or concerning whom
the taxpayer has realized an item of income.
Roger M. Schrimp, James F. Lewis, and Steven G. Pallios, for
petitioners.
Michael F. Steiner, Julie A. Howell, and Dale A. Zusi, for
respondent.
GERBER, Judge: In separate notices of deficiency,
respondent determined deficiencies in petitioners’ Federal income
tax and accuracy-related penalties under section 66622 for the
1992, 1993, and 1994 taxable years as follows:
2 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the taxable years under
consideration, and Rule references are to the Tax Court Rules of
Practice and Procedure.
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