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WILLOUGHBY v. COMMISSIONER

Docket No. 24025-87.

68 T.C.M. 428 (1994)

T.C. Memo. 1994-398

William W. Willoughby v. Commissioner.

United States Tax Court.

Filed August 18, 1994.

Attorney(s) appearing for the Case

Jeffrey A. Donner, for the petitioner. Patricia A. Taylor, for the respondent.

Memorandum Opinion

COLVIN, Judge:

This matter is before the Court on the parties' motion and cross-motion for summary judgment under Rule 121.

After concessions,1 the issues for decision are:

(1) Whether the time to assess tax for 1979 and 1980 has expired. This depends on the validity of consents to extend the statute of limitations for 1979 and 1980. We hold that the consents are valid and that assessment of...

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