- 17 - Period of Limitations/Deficiencies As we noted supra, respondent concedes that absent a finding of fraud the period of limitations for all of the years in issue expired. Accordingly, petitioners are not liable for the deficiencies, additions to tax, or penalties for the years in issue. To reflect the foregoing, Decisions will be entered for petitioners.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011