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BAXTER v. COMMISSIONER

Docket No. 28244-88.

62 T.C.M. 92 (1991)

T.C. Memo. 1991-312

Ralph A. Baxter and Marjorie J. Baxter v. Commissioner.

United States Tax Court.

Filed July 9, 1991.

Attorney(s) appearing for the Case

Robert S. Schriebman, 21515 Hawthorne Blvd., Torrance, Calif., for the petitioners.

Michael R. McMahon, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge.

This matter is before us on petitioners' motion for summary judgment. The basis for petitioners' motion is the allegation that the 3-year period under section 6501(a)1 limiting respondent's authority to assess tax deficiencies against petitioners for 1977, 1978, 1980, and 1982 expired before respondent mailed his notice of deficiency...

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