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considered filed on the last day. Thus, although petitioners
filed their tax return for 2000 in February 2001, the return is
deemed to have been filed on Monday, April 16, 2001. See sec.
7503. It follows that the notice of deficiency dated March 24,
2004, upon which this case is based, was issued within the
applicable 3-year period of limitations.
Consistent with the preceding discussion, we shall grant
respondent’s Motion For Summary Judgment.
To reflect the foregoing,
An Order and Decision will
be entered granting respondent’s
Motion For Summary Judgment.
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Last modified: May 25, 2011