ROSS, Senior Circuit Judge.
William F. Smith appeals from the grant of summary judgment in favor of the Commissioner of the Internal Revenue Service (Commissioner), based on the finding that the Commissioner's assessment of an increased tax deficiency was not precluded by the statute of limitations. We affirm.
I.
William F. Smith owned an interest in the partnerships of James Associates, Ltd. and Silverton 1976 during the years at issue in this case...
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