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ADLER v. COMMISSIONER

Docket No. 19836-83.

85 T.C. 535 (1985)

CHARLES ADLER AND EDWINA ADLER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 7, 1985.

Attorney(s) appearing for the Case

Alan A. Davidson, for the petitioners.

Caroline R. Ades, for the respondent.

OPINION

KÖRNER, Judge:

Respondent determined a deficiency in petitioners' income tax for the calendar year 1978 in the amount of $25,765. After agreement by the parties on an unrelated matter,1 the sole issue which we must determine is whether respondent's statutory notice of deficiency for 1978 was issued after the expiration of the effective statute of limitations under section 6501.2

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