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CAGLE v. COMMISSIONER

Docket No. 22005-88.

60 T.C.M. 1278 (1990)

T.C. Memo. 1990-593

Lewis Vernon Cagle and Stephanie Cagle, and C. Everett and Joyce Alger v. Commissioner.

United States Tax Court.

Filed November 20, 1990.

Attorney(s) appearing for the Case

James E. Bachman, 2580 S. 90th St., Omaha, Neb., for the petitioners Cagle, and Jeffrey W. Meyers, 10855 W. Dodge Rd., Omaha, Neb., for the petitioners Alger. J. Anthony Hoefer, for the respondent.

Memorandum Opinion

GERBER, Judge:

The Cagles and Algers originally joined in a single petition in which each set of petitioners made separate allegations of error with respect to separate determinations of respondent. The Cagles have entered into a settlement stipulation regarding their assignments of error. With respect to the Algers, their sole assignment of error concerns the timeliness of respondent's notice of deficiency, a controversy which presents...

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