Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined a deficiency in the amount of $104,352 in petitioners' Federal income tax for 1976. The parties agree that there is a deficiency in the amount of $70,548 in petitioners' 1976 Federal income tax if the notice of deficiency was timely mailed. The sole issue to be decided is whether assessment of the determined deficiency is barred by the 3-year limitations period prescribed by...
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