Gary M. Emmons and Martha C. Emmons v. Commissioner of Internal Revenue

W. EUGENE DAVIS, Circuit Judge:

Gary M. Emmons and Martha C. Em-mons (the taxpayers) appeal the tax court’s order sustaining the Commissioner of Internal Revenue’s (the Commissioner’s) determination of tax deficiencies. We affirm.

I

The taxpayers sought review in the tax court for deficiencies the Commissioner assessed against them for their 1981 and 1982 returns. The Tax Court sustained the Commissioner’s determination of deficiencies.

The only issue on appeal is whether the statute of limitations had run on the Commissioner’s ability to assess deficiencies. The returns at issue were due on…