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STENCLIK v. C.I.R.

No. 1408, Docket 90-4021.

907 F.2d 25 (1990)

Richard R. STENCLIK and Dolores Stenclik, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided June 26, 1990.

Attorney(s) appearing for the Case

Basil Tzetzo, Buffalo, N.Y., for petitioners-appellants.

Charles Bricken (Shirley D. Peterson, Asst. Atty. Gen., Gary R. Allen, Richard Farber, Tax Div., Dept. of Justice, Washington, D.C., of counsel), for respondent-appellee.

Before VAN GRAAFEILAND, MESKILL and WALKER, Circuit Judges.

WALKER, Circuit Judge:

This appeal comes to us from a ruling by the United States Tax Court (Lawrence A. Wright, Judge) that the Internal Revenue Service ("IRS") was not time-barred from assessing in 1988 a deficiency in 1980 federal income taxes due from Richard R. and Dolores Stenclik ("taxpayers"). The sole issue before us is the timeliness of the statutory notice of the 1980 income tax deficiency that was sent to taxpayers in June, 1988. The taxpayers'...

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