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DUNCAN v. COMMISSIONER

Docket No. 15988-87.

56 T.C.M. 1073 (1989)

T.C. Memo. 1989-22

Robert E. Duncan and Linda L. Duncan v. Commissioner.

United States Tax Court.

Filed January 12, 1989.

Attorney(s) appearing for the Case

G. Dana French, for the petitioners. Stephen R. Asmussen, for the respondent.

Memorandum Opinion

GERBER, Judge:

This matter is before the Court on petitioners' motion for summary judgment. Petitioners claim that the 3-year statutory period of limitations under section 6501(a)1 expired, barring the assessment of income tax for the 1981 taxable year. For the reasons discussed below, petitioners' motion is denied.

Petitioners filed their 1981 Federal income tax return on October 18, 1982. On October...

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