COLEMAN v. COMMISSIONER

Docket No. 1486-86.

94 T.C. 82 (1990)

PHILIP AND GERALDINE COLEMAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 26, 1990.


Attorney(s) appearing for the Case

Michael H. King and Lawrence H. Jacobson, for the petitioners.

John P. Jankowski and Donna Hansberry, for the respondent.


GERBER, Judge:

We consider here whether respondent timely mailed the notice of deficiency or whether the period has expired for the assessment and collection of any deficiencies in tax for years 1977 through 1981. We previously denied petitioners' motion for partial summary judgment on this issue and ordered that separate proceedings be conducted on the question of the expiration of the period of limitation on assessment...

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