-22-
indefinitely. See sec. 6501(c)(1); Sam Kong Fashions, Inc. v.
Commissioner, T.C. Memo. 2005-157. Accordingly, respondent is
not barred from assessing petitioners’ deficiencies. See sec.
6501(c)(1).
Respondent would not be barred from assessing petitioners’
taxes for the years at issue even if we had not found that
petitioners had filed false and fraudulent returns. The
limitations period is extended to 6 years if a taxpayer omits
from gross income an amount that is 25 percent of the amount the
taxpayer stated in the return. Sec. 6501(e)(1)(A). Both
petitioners omitted from gross income amounts vastly in excess of
25 percent of the amounts stated on the returns, and the
limitations period would be extended to 6 years. Respondent
issued deficiency notices within 6 years of the due dates of the
returns and is thus not barred from assessing petitioners’ taxes.
We have considered all remaining arguments the parties made
and, to the extent not addressed, we conclude they are
irrelevant, moot, or meritless.
To reflect the foregoing,
Decisions will be entered
for respondent.
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Last modified: November 10, 2007