In Fairbank v. Commissioner, T.C. Memo 2023-19 (Feb. 23, 2023), the Tax Court ruled that the three-year statute of limitations did not bar assessment. On April 12, 2018, the IRS issued to Leigh and Barbara Fairbank a notice of deficiency for tax years 2003-2009. Because the Fairbanks timely filed their tax returns, they
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