MEMORANDUM OPINION
SWIFT, Judge:
This case is before the Court under Rule 121
As a matter of law, petitioner contends that respondent's notice of deficiency in income tax to petitioner for 1986 in the amount of $375,173 is barred by the 3-year period of limitation under section 6501 and that the mitigation provisions of the Code (specifically the circumstance of adjustment...
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