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BACHNER v. C.I.R.

No. 95-7121.

81 F.3d 1274 (1996)

Ronald C. BACHNER, Appellant, v. COMMISSIONER OF INTERNAL REVENUE SERVICE.

United States Court of Appeals, Third Circuit.

Decided April 17, 1996.

Attorney(s) appearing for the Case

Dennis P. Craig (Argued), Pittsburgh, PA, for Appellant.

Gary R. Allen, Ann B. Durney, Kenneth Rosenberg (Argued), United States Department of Justice, Tax Division, Washington, DC, for Appellee.

Before: SLOVITER, Chief Judge, COWEN and GARTH, Circuit Judges.

OPINION OF THE COURT

SLOVITER, Chief Judge.

Ronald C. Bachner appeals from the decision of the United States Tax Court sustaining the determination of the Commissioner of Internal Revenue of deficiencies in and additions to Bachner's federal income taxes for the tax years 1984 and 1985. Bachner claims that the applicable statute of limitations bars assessment for each year.

I.

Facts and Procedural History

In 1984 and 1985...

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