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b. Mr. Coyle
Because the underpayments of tax due from Mr. Coyle were
attributable to fraud under section 6663, respondent is not
barred from assessing the deficiencies determined against Mr.
Coyle for 1992 and 1993. Sec. 6501(c)(1). Because we have
concluded that the periods of limitations have not expired under
section 6501(c)(1) with respect to Mr. Coyle, we need not
consider whether section 6501(e) is applicable.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered for
respondent in docket No. 12012-99S
and for petitioner in docket No.
12061-99S.
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