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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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