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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.
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Last modified: May 25, 2011