Memorandum Findings of Fact and Opinion
PARR, Judge:
This case is before the Court on petitioner's motion for summary judgment and respondent's cross-motion for partial summary judgment. The issue for decision is whether the period of limitations expired before respondent mailed a notice of deficiency to petitioner. This issue is dependent upon the legal effect of a Form 872-A (Special Consent to Extend the Time to Assess Tax) executed by the parties. If...
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