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LIFTER v. COMMISSIONER

Docket No. 5765-72.

59 T.C. 818 (1973)

DANIEL LIFTER AND HELENE LIFTER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 12, 1973.

Attorney(s) appearing for the Case

Richard B. Wallace and Harold Tannen, for the petitioners.

Vernon J. Owens and Marlene Gross, for the respondent.

SIMPSON, Judge:

The respondent determined a deficiency of $100,069.20 in the petitioners' Federal income tax for the year 1968. This proceeding arises from a motion by the petitioners to dismiss for lack of jurisdiction on the ground that no proper statutory notice of deficiency was issued. At trial, the petitioners' motion was amended to request a ruling that, because no proper statutory notice was given within the 3-year statute of limitations, assessment...

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