Carpenter Family Invs. v. Comm’r, 2011 U.S. Tax Ct..
In Carpenter Family Invs. v. Comm'r, 2011 U.S. Tax Ct. LEXIS 17 (T.C. Apr. 25, 2011) , a FPAA issued after the 3-year limitations period was held untimely under IRC § 6501(a) . At issue was a "series of