HULL, Circuit Judge:
The Internal Revenue Code ("Code") requires the Internal Revenue Service ("IRS") to assess tax deficiencies within certain statutory limitations periods. The Code, however, provides for suspension of certain limitations periods. This appeal involves one such statutory-suspension section. Specifically, § 6503(a)(1) of the Code suspends the running of the limitations period when "a proceeding in respect of the deficiency is placed on the docket...
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