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SCHERR v. COMMISSIONER

Docket No. 25547-89.

61 T.C.M. 2049 (1991)

T.C. Memo. 1991-92

Barry A. Scherr v. Commissioner.

United States Tax Court.

Filed March 4, 1991.

Attorney(s) appearing for the Case

R. Stephen Scott, 415 S. 7th St., Springfield, Ill., for the petitioner. Michael W. Bitner and Jeff P. Ehrlich, for the respondent.

Memorandum Opinion

GERBER, Judge:

Petitioner moved for summary judgment pursuant to Rule 121.1 The sole issue for our consideration is whether the assessment of the deficiencies and additions to tax determined by respondent is barred by the statute of limitations.

By statutory notice of deficiency dated August 1, 1989, respondent determined deficiencies in and additions to petitioner's Federal income taxes in the following...

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