Memorandum Findings of Fact and Opinion
PARR, Judge:
Respondent determined deficiencies and additions to tax against petitioners for the 1976, 1977 and 1978 taxable years. The issue is whether the statute of limitations has expired for the years before us, thereby barring assessment of the deficiencies and additions to tax. This issue was severed from the remaining issues raised in the petition, by agreement of the parties and the Court.
Petitioners...
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