Richard R. Stenclik and Dolores Stenclik v. Commissioner of Internal Revenue

WALKER, Circuit Judge:

This appeal comes to us from a ruling by the United States Tax Court (Lawrence A. Wright, Judge) that the Internal Revenue Service (“IRS”) was not time-barred from assessing in 1988 a deficiency in 1980 federal income taxes due from Richard R. and Dolores Stenclik (“taxpayers”). The sole issue before us is the timeliness of the statutory notice of the 1980 income tax deficiency that was sent to taxpayers in June, 1988. The taxpayers’ primary argument is that, although they agreed to an open-ended extension of the limitations period in 1983, that period nonetheless…