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OVERSTREET v. COMMISSIONER

Docket No. 2659-00.

81 T.C.M. 1040 (2001)

T.C. Memo. 2001-13

Gary F. and Helen Overstreet, v. Commissioner.

United States Tax Court.

Filed January 22, 2001.

Attorney(s) appearing for the Case

Gary F. Overstreet and Helen Overstreet, pro sese.

Robert H. Schorman, Jr., for the respondent.

MEMORANDUM OPINION

FOLEY, Judge:

By notice dated January 6, 2000, respondent determined a deficiency of $47,582 relating to petitioners' 1992 Federal income taxes. All section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. The sole issue for determination is whether respondent issued the notice of deficiency within the limitations period.

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