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STENCLIK v. COMMISSIONER

Docket Nos. 5895-85, 28295-87.

56 T.C.M. 1059 (1989)

T.C. Memo. 1989-19

Richard R. Stenclik and Dolores Stenclik v. Commissioner.

United States Tax Court.

Filed January 11, 1989.

Attorney(s) appearing for the Case

Basil Tzetzo, P.O. Box 470, Buffalo, N.Y., for the petitioners. Jerome F. Warner, for the respondent.

Memorandum Opinion

PANUTHOS, Special Trial Judge:

These cases are before the Court on respondent's Motions for Partial Summary Judgment.1 The issue for decision is whether the period of limitations expired prior to the issuance of the notices of deficiency. This issue is dependent upon the legal effect of Forms 872-A (Special Consents to Extend the Time to Assess Tax) executed by the parties.

Respondent, in a notice of...

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