- 28 - Stone v. Commissioner, 22 T.C. 893 (1954)); see also Ziegler v. Commissioner, T.C. Memo. 2003-282. Here, the parties have stipulated that “With petitioner’s permission, Bonnie E. McNamara signed petitioner’s name on their joint income tax returns for the taxable years at issue.” We find that petitioner manifested his intent to file joint Federal income tax returns by granting Ms. McNamara permission to sign his name on the returns in issue. Because petitioner and Ms. McNamara intended to file joint Federal income tax returns, we find that petitioner is liable for the deficiencies, additions to tax, and penalties. See sec. 6013(d)(3). VII. Period of Limitation Section 6501(a) generally requires the Commissioner to assess any tax within 3 years after the return was filed. Section 6501(c) lists exceptions to the 3-year limitation on assessments under section 6501(a). In the case of false or fraudulent returns, section 6501(c)(1) provides that the tax may be assessed at any time. Because we find that petitioner’s deficiencies in 1988, 1989, and 1990 were the result of fraud, the statute of limitations does not bar the assessment of tax for the years in issue. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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