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REUTER v. COMMISSIONER

Docket No. 32359-83.

51 T.C.M. 99 (1985)

T.C. Memo. 1985-607

Kenneth J. Reuter and Eleanor R. Reuter v. Commissioner.

United States Tax Court.

Filed December 16, 1985.

Attorney(s) appearing for the Case

Charles J. Reilly and Joseph D. Tudino, 1040 Fleet National Bank Bldg., Providence, R.I., for the petitioners. Maureen T. O'Brien, for the respondent.

Memorandum Findings of Fact and Opinion

GOFFE, Judge:

The Commissioner determined a deficiency in petitioners' Federal income tax for the taxable year 1978 in the amount of $12,304.53. The Commissioner also imposed an addition to tax under section 6653(a)(1)1 in the amount of $615.23.

The sole issue before us is whether the period of limitations for assessment of tax against petitioners is extended to 6 years under section...

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