Ralph K. Moore (78-1164), Blue Ridge Transportation Company, Inc. (78-1165) v. Commissioner of Internal Revenue, (78-1164/5)

ORDER

On November 19,1971, the Commissioner of Internal Revenue (the “Commissioner”) mailed a deficiency notice to the Appellants with respect to their 1963 and 1964 return. At the time the deficiency notices were mailed to Appellants, the period for assessment of an income tax deficiency for 1963 against the Moores, and for 1963 and 1964 against the Blue Ridge Transportation Company had expired unless fraudulent returns were filed. 26 U.S.C. § 6501(c)(1). Similarly, the period for assessment of a deficiency for 1964 against the Moore’s had expired unless a fraudulent return was filed or…