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DAIGLE v. COMMISSIONER

Docket No. 20512-85.

52 T.C.M. 1054 (1986)

T.C. Memo. 1986-558

Charles F. Daigle and Linda A. Daigle v. Commissioner.

United States Tax Court.

Filed November 20, 1986.

Attorney(s) appearing for the Case

Charles F. Daigle, pro se, Pasadena, Tex. Michael A. Urban, for the respondent.

Memorandum Findings of Fact and Opinion

COUVILLION, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7456(d) (redesignated as section 7443A by the Tax Reform Act of 1986, Pub.L. 99-514, section 1556, 100 Stat. —) of the Code1 and Rules 180, 181, and 182.

The threshhold issue is whether the statute of limitations on assessment for 1980 expired prior to issuance of the notices of...

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