SANZOGNO v. COMMISSIONER

Docket No. 2278-70.

60 T.C. 947 (1973)

NINO SANZOGNO, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 20, 1973.


Attorney(s) appearing for the Case

Barry L. Weinstein, for the petitioner.

Alan M. Jacobson, for the respondent.


SUPPLEMENTAL OPINION

GOFFE, Judge:

Respondent determined deficiencies in the Federal income tax of petitioner for the taxable years 1965 and 1966 in the amounts of $1,604.10 and $4,834, respectively.

Petitioner filed a motion to sever the issue of whether assessment of the tax for the taxable year 1965 was barred by the statute of limitations. We granted the motion and the facts relating to that year were stipulated by the parties. We decided...

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