WIENER, Circuit Judge:
Petitioner-Appellant Jerry S. Payne appeals an adverse decision of the Tax Court, which awarded Respondent-Appellee Commissioner of Internal Revenue ("the government" or "the IRS") $438,722 in delinquent income taxes and penalties for tax years 1987 and 1988, plus interest. As a general rule, the IRS must assess taxes within three years following the date that the return is filed. Here, the IRS did not send Payne a notice of deficiency (an event...
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