William H. Kinsey, and Estate of Irene S. Kinsey, Deceased, William H. Kinsey v. Commissioner of Internal Revenue

TASHIMA, District Judge:

This appeal from the Tax Court involves income taxes payable for the years 1977 and 1978. 1 Only two issues are presented on appeal: (1) whether the deficiency notices for 1977 were timely issued by the Internal Revenue Service (the “Service” or “I.R.S.”); and (2) whether the deficiencies determined in the 1977 notices were within the restriction contained in the Form 872-A executed by the parties. 2 The Tax Court held that the statutory notice of deficiency for 1977 was timely issued within the period of the Form 872-A waiver of the statute of limitations for…