Arthur I. Appleton, Jr. , and The Government of the United States Virgin Islands, Intervenor v. Commissioner

OPINION

Jacobs, Judge:

This case is before the Court on petitioner’s motion for summary judgment filed pursuant to Rule 121. The specific question to be decided is whether the section 6501 period of limitations on assessment and collection expired before the date respondent mailed petitioner the notice of deficiency. For the reasons set forth infra, we will grant petitioner’s motion.

All section references are to the Internal Revenue Code (Code) in effect for the years at issue unless otherwise indicated, and all Rule references are to the Tax Court Rules of Practice and Procedure. At the time…