Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, in a notice of deficiency dated October 11, 1985, determined deficiencies in petitioner's 1976, 1977 and 1979 Federal income taxes in the amounts of $45,055.68, $21,571.20 and $7,437.02, respectively. Petitioner, on November 29, 1985, filed a timely petition and by a motion filed August 20, 1986, seeks summary judgment on the ground that the statute of limitations on assessment and collection...
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