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The running of the period of limitations is suspended when a
notice of deficiency is mailed, and, if a proceeding with respect
to the deficiency is brought before this Court, the period of
limitations remains suspended until the decision of this Court
becomes final and for 60 days thereafter. See secs. 6213(a),
6503(a)(1); sec. 301.6503(a)-1, Proced. & Admin. Regs. Thus, the
time for assessment of tax for 1994 and 1995 remains open until
60 days after our decision in this case becomes final.
To reflect the foregoing,
Decision will be
entered for respondent.
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Last modified: May 25, 2011