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CANNON v. COMMISSIONER

Docket No. 35354-87.

60 T.C.M. 391 (1990)

T.C. Memo. 1990-410

Richard D. and Mary E. Cannon v. Commissioner.

United States Tax Court.

Filed August 2, 1990.

Attorney(s) appearing for the Case

Jay J. Freireich, 256 Columbia Turnpike, Florham Park, N.J., for the petitioners. Jane B. Wilson, for the respondent.

Memorandum Findings of Fact and Opinion

WELLS, Judge:

Respondent determined the following deficiencies in petitioners' Federal income tax:

Taxable Year Ended              Deficiency

December 31, 1975 ...........    $3,792
December 31, 1976 ...........     2,884

The sole issue presented is whether assessments for the years in issue are barred by the applicable period of limitations. Petitioners do not contest the...

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