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on the time to assess tax applies. Wood v. Commissioner, 245
F.2d 888, 893-895 (5th Cir. 1957), affg. in part and revg. in
part T.C. Memo. 1955-301; Bardwell v. Commissioner, 38 T.C. 84,
92 (1962), affd. 318 F.2d 786 (10th Cir. 1963). Because
respondent has proved that petitioner’s underpayment of tax for
each year at issue was due to fraud, the assessment of tax
deficiencies for each year involved is not barred by the statute
of limitations. Sec. 6501(c)(1); Meier v. Commissioner, 91 T.C.
at 303.
To reflect the foregoing and concessions by respondent,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011