BUFFERD v. C.I.R.

No. 214, Docket 91-4099.

952 F.2d 675 (1992)

Sheldon B. BUFFERD; Phyllis Bufferd, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided January 3, 1992.


Attorney(s) appearing for the Case

Stuart J. Filler, University of Bridgeport School of Law Tax Clinic, Bridgeport, Conn. (Toni Robinson, Joseph A. Kubic, Craig H. Rein, University of Bridgeport School of Law Tax Clinic, of counsel), for petitioners-appellants.

Janet K. Jones, Tax Div., Dept. of Justice, Washington, D.C. (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, and Robert S. Pomerance, Tax Div., Dept. of Justice, of counsel), for respondent-appellee.

Before MESKILL, WINTER and ALTIMARI, Circuit Judges.


MESKILL, Circuit Judge:

Sheldon Bufferd appeals from a decision of the United States Tax Court imposing a tax deficiency on him for the year 1979. The sole issue on appeal is whether the Commissioner of Internal Revenue (Commissioner) timely assessed the deficiency. The tax court held that the Commissioner was not barred by the limitation provision of the Internal Revenue Code.

We affirm.

BACKGROUND

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