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Accordingly, the period for assessment for 1992, 1993, or
1994 did not remain open under the provisions of section
6501(c)(1). Because of petitioner’s concession that the 1994
assessment period was open under section 6501(e), petitioner
remains liable for an income tax deficiency based on the agreed
underpayment for his 1994 tax year.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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