ROSBERG v. COMMISSIONER

Docket No. 12328-87.

55 T.C.M. 1114 (1988)

T.C. Memo. 1988-267

David Rosberg v. Commissioner.

United States Tax Court.

Filed June 22, 1988.


Attorney(s) appearing for the Case

Montie S. Day, 80 Swan Way, Oakland, Calif., for the petitioner. Eric P. Doerring, for the respondent.


Memorandum Opinion

SHIELDS, Judge:

This matter is before us at this time on petitioner's motion for summary judgment to the effect that the assessment of the deficiencies in and additions to tax determined by respondent is barred by the statute of limitations. In a notice of deficiency mailed to petitioner on February 10, 1987, respondent determined deficiencies in and additions to his income taxes as follows:

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