- 12 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011