Memorandum Findings of Fact and Opinion
WHALEN, Judge:
This case is before the Court to decide a motion filed by petitioner in the nature of a motion for partial summary judgment. The sole issue for decision is whether the notice of deficiency was issued after the expiration of the period of limitations on assessments under section 6501(a) for the year 1983. All section references in this opinion are to the Internal Revenue Code, as amended. Resolution of...
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