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WALDEN v. COMMISSIONER

Docket No. 32291-84.

90 T.C. 947 (1988)

PAUL S. WALDEN AND MARIE C. WALDEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 10, 1988.

Attorney(s) appearing for the Case

John H. Birkeland and Neil M. Goff, for the petitioners.

Michael J. Cooper, for the respondent.

JACOBS, Judge:

Respondent determined a deficiency in petitioners' 1979 Federal income taxes in the amount of $54,469 and an addition to tax pursuant to section 6651(a)(1)1 in the amount of $13,145.25. The issue presented for decision is whether the period for assessing the deficiency against petitioners expired prior to the date of issuance of the notice of deficiency.2...

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