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returns, we conclude that only the 1994 return was mailed on
April 15, 1998. We find that petitioner has not established that
the period of limitations for assessing the tax liabilities for
1996 and 1997 had expired prior to the mailing of the notices of
deficiency for those years.
Reviewed and adopted as the report of the Small Tax Case
Division.
An appropriate order will
be issued.
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