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ELDEN v. COMMISSIONER

Docket No. 9493-78.

43 T.C.M. 520 (1982)

T.C. Memo. 1982-71

William Elden and Elizabeth R. Elden v. Commissioner.

United States Tax Court.

Filed February 11, 1982.

Attorney(s) appearing for the Case

William Elden, pro se. William E. Bogner, for the respondent.

Memorandum Opinion

WILBUR, Judge:

This matter comes before the Court on respondent's motion for partial summary judgment. A hearing was held after which petitioner1 submitted a written brief on the issue presented.

The petition in this case alleges "that the Notice of Deficiency was issued more than three years after the return was filed and is barred by section 6501(a)."2 Respondent affirmatively...

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