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attributable to $24,594 of the unreported income was not
attributable to fraud.
IV. Statute of Limitation
Petitioners argue that the 3-year period of limitations on
assessment had expired when respondent issued the notices of
deficiencies. Because the 3-year period of limitations of
section 6501(a) ended before respondent issued the notices of
deficiency, respondent relies on the exception to the general
period of limitations provided in section 6501(c)(1).
Section 6501(c)(1) provides that “In the case of a false or
fraudulent return with the intent to evade tax, the tax may be
assessed, or a proceeding in court for collection of such tax may
be begun without assessment, at any time.” Because we have held
that petitioners filed fraudulent individual and corporate
income tax returns for the years in issue, we hold that the
period of limitations does not bar the assessment of the
deficiencies and penalties in these cases. Sec. 6501(c)(1).
To reflect the foregoing,
Decisions will be entered
under Rule 155.
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