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APPLETON v. COMMISSIONER

Docket No. 7717-10.

140 T.C. 273 (2013)

140 T.C. No. 14

ARTHUR I. APPLETON, JR., PETITIONER, AND THE GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS, INTERVENOR v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 22, 2013.

Attorney(s) appearing for the Case

Randall P. Andreozzi, Edward Doyle Fickess, Ryan M. Murphy, Teia M. Bui, and Michael J. Tedesco, for petitioner.*

Vincent F. Frazer, Barry J. Hart, Gene C. Schaerr, Tamika M. Archer, and Christopher M. Bruno, for intervenor.

Ladd Christman Brown, Jr., Justin L. Campolieta, Randall L. Eager, Jr., Brian J. Bilheimer, Edward J. Laubach, Jr., James G. Hartford, and Jacob Russin, for respondent.

OPINION

JACOBS, Judge:

This case is before the Court on petitioner's motion for summary judgment filed pursuant to Rule 121. The specific question to be decided is whether the section 6501 period of limitations on assessment and collection expired before the date respondent mailed petitioner the notice of deficiency. For the reasons set forth infra, we will grant petitioner's motion.

All section references are to the Internal Revenue...

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