T.C. Memo. 2001-251
UNITED STATES TAX COURT
MICHAEL SKLAR AND MARLA SKLAR, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 395-01. Filed September 21, 2001.
Michael Sklar and Marla Sklar, pro sese.
Steven M. Roth, for respondent.
MEMORANDUM OPINION
GERBER, Judge: Petitioners, under Rule 121,1 moved for
summary judgment on the question of whether the period for
assessment had expired at the time respondent conceded an
1 Rule references are to the Tax Court Rules of Practice and
Procedure. Section references are to the Internal Revenue Code,
in effect for the period under consideration.
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