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HOLOF v. COMMISSIONER

Docket No. 33874-84.

54 T.C.M. 959 (1987)

T.C. Memo. 1987-540

Harry Holof and Norma Holof v. Commissioner.

United States Tax Court.

Filed October 22, 1987.

Attorney(s) appearing for the Case

John J. O'Toole, G. Michael Saran, 101 Eisenhower Parkway, Roseland, N.J., and Edwin Fradkin, for the petitioners. William S. Garofalo, for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined deficiencies in petitioners' Federal income tax as follows:

Taxable Year Ended              Amount

December 31, 1976 ...........   $27,710
December 31, 1977 ...........     1,272

The sole issue before us is whether the issuance of the notice of deficiency is barred by the statute of limitations, section 6501(a) and (c)(4).1<...

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