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UNILEVER SUPERANNUATION TRUSTEES LTD. v. COMMISSIONER

Docket No. 10022-97.

77 T.C.M. 1494 (1999)

T.C. Memo. 1999-67

Unilever Superannuation Trustees Limited v. Commissioner.

United States Tax Court.

Filed March 5, 1999.

Attorney(s) appearing for the Case

K. Peter Schmidt, Washington, D. C., for the petitioner. Gary D. Kallevang, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

Petitioner moves for summary judgment, asserting that section 6501 does not allow respondent to assess tax for the years in issue. Respondent moves for partial summary judgment, asserting primarily that the notices of deficiency are timely under section 6501(c)(3). Respondent issued the notices of deficiency to petitioner on December 19, 1996, after determining deficiencies in the 1991, 1992, and 1993 income tax of Unilever...

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