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FREEDMAN v. COMMISSIONER

Docket No. 7040-84.

51 T.C.M. 1264 (1986)

T.C. Memo. 1986-257

Irving S. Freedman and Harriette Freedman v. Commissioner.

United States Tax Court.

Filed June 23, 1986.

Attorney(s) appearing for the Case

Benjamin Lewis, 989 Avenue of the Americas, New York, N.Y., for the petitioners. Norman A. Segal, for the respondent.

Memorandum Opinion

WILBUR, Judge:

Respondent determined the following deficiencies in petitioners Federal income taxes:

Year                Deficiency

1971 .............   $16,170
1972 .............    17,103
1973 .............    37,077
1974 .............     8,949

Petitioners filed a motion for partial summary judgment pursuant to Rule 121,1 claiming that the statute of limitations...

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