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Discussion
We decide whether respondent timely issued the notice of
deficiency to the Greenfields within the applicable period of
limitations provided by section 6501(a). Respondent argues that
the notice of deficiency was timely because the Greenfields’
execution of Form 872-A extended the period of limitations under
section 6501(c)(4). Petitioners argue that the notice of
deficiency was untimely. Alternatively, petitioners argue, the
extension, if effective, applies only to the tax deficiency and
not to the increased rate of interest. We conclude that the
notice of deficiency was timely. We also conclude that the Form
872-A applies to both the income tax deficiency and the increased
rate of interest.
A. Burden of Proof
As a general rule, Federal income tax must be assessed
within 3 years after a tax return is filed. See sec. 6501(a).
That period may be extended, however, by written agreement
between the taxpayer and the Commissioner made before expiration
of the general 3-year period. See sec. 6501(c)(4).
The bar of limitations is an affirmative defense, and
taxpayers raising it must specifically plead it and carry the
burden of proof. See Rules 39, 142; Adler v. Commissioner, 85
T.C. 535, 540-541 (1985). A taxpayer can establish a prima facie
case by showing that the Commissioner mailed the notice of
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