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FRIELING v. COMMISSIONER

Docket No. 10753-80.

81 T.C. 42 (1983)

GERALD H. FRIELING, JR., AND JOAN L. FRIELING, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 20, 1983.

Attorney(s) appearing for the Case

Richard A. Hanson, for the petitioners.

Val J. Albright, for the respondent.

PARKER, Judge:

Respondent determined a deficiency in petitioners' 1976 Federal income tax in the amount of $7,040.1 The case is presently before the Court on petitioners' motion to dismiss for lack of a timely notice of deficiency. See Rule 53, Tax Court Rules of Practice and Procedure.

The general issue for decision is whether a valid notice of deficiency was issued within the 3-year statute of limitations provided in section...

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