Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined a $171,203 deficiency in petitioners' joint Federal income tax return for calendar year 1978.
The issues for decision are whether petitioners' restricted "Form 872M" is valid to extend the period of assessment and to limit their determined deficiency to a maximum of $50.00, and if not, whether petitioners are estopped from asserting the statute of limitations as a defense...
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