Graham v. Commissioner

MEMORANDUM *

Appellants Albert M. Graham and Martha A. Graham appeal a decision of the United States Tax Court, upholding the Commissioner’s determination of deficiencies in Appellants’ federal income tax and imposition of penalties. Appellants contend that the Tax Court erred in determining their tax liability and in finding that Graham acted fraudulently in omitting certain items of income from Appellants’ income tax returns.1 We have jurisdiction pursuant to 26 U.S.C. § 7482, and we affirm in all respects.

We agree with the Tax Court that the three-year limit found in 26 U.S.C. § 6501(a)…