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ICI PENSION FUND v. COMMISSIONER

Docket No. 10030-97.

112 T.C. 83 (1999)

ICI PENSION FUND, ICI PENSIONS TRUSTEE LIMITED, TRUSTEE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 5, 1999.

Attorney(s) appearing for the Case

K. Peter Schmidt, for petitioner.

Gary D. Kallevang, for respondent.

OPINION

LARO, Judge:

ICI Pension Fund, ICI Pensions Trustee Limited, Trustee, moves for summary judgment, asserting that section 6501 does not allow respondent to assess tax for either year in issue. Respondent moves for partial summary judgment, asserting primarily that the notices of deficiency are timely under section 6501(c)(3). Respondent issued the notices of deficiency to ICI Pension Fund, ICI Pensions Trustee Limited, Trustee, on December...

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