MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge:
In a notice of deficiency issued on January 22, 1996, respondent determined deficiencies, additions to tax, and civil fraud penalties relating to John and Mary Maloney's 1984 and 1986 Federal income taxes. The parties have settled all issues relating to the 1984 tax year. Among the issues relating to the 1986 tax year is whether the period of limitation on assessment has expired. We conclude that assessment...
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