Eddie Lee Williams - Page 12

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               Finally, we briefly address an issue raised by respondent at           
          trial concerning the application of the statute of limitations on           
          collections.  A period of limitations on collections begins when            
          an assessment of tax has been made, including a jeopardy                    
          assessment, and generally runs for 10 years.  Sec. 6502(a)(1).              
          However, where a taxpayer petitions this Court in response to a             
          statutory notice of deficiency, the period of limitations for               
          collection of the deficiency is suspended until 60 days after the           
          Court’s decision becomes final.  Sec. 6503(a)(1).  Thus, the                
          period of limitations on collections has not expired in this                
          case.  See Estate of Iaconi v. Commissioner, T.C. Memo. 1961-106.           
               To reflect the foregoing,                                              
                                             Decision will be entered for             
                                        respondent except with respect to             
                                        the section 6654(a) addition to               
                                        tax for 1989.                                 

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