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WORDEN v. COMMISSIONER

Docket No. 34033-87.

67 T.C.M. 2835 (1994)

T.C. Memo. 1994-193

Mickey L. and Virginia L. Worden v. Commissioner.

United States Tax Court.

Filed April 28, 1994.

Attorney(s) appearing for the Case

Mickey L. Worden, pro se. Donald E. Edwards, for the respondent.

Supplemental Memorandum Opinion

WHALEN, Judge:

This case is before the Court to decide Petitioners' Motion to Dismiss on the ground that assessment of the subject deficiency for 1982 is barred by the period of limitations on assessments set forth in section 6501(a). Petitioners filed their motion after the United States Court of Appeals for the Tenth Circuit partially reversed our opinion, filed at T.C. Memo. 1992-447

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