Problems Bill and Mary were married and filed joint federal income tax returns. They received a letter from the IRS dated November 10, 20x5, telling them that their returns for the years 20x3 and 20x4 were under examination, and asking them to call the Revenue Agent assigned to the case to schedule a meeting. Bill and Mary engaged a lawyer to represent them in the examination. Bill and Mary separated in mid-20x5 and were considering a divorce. Mary didn't trust Bill, and filed a separate return for that year. Bill failed to file a return at all. The 20x3 and 20x4 returns showed as their address the home that they had occupied together. Mary continued to live there after they were separated. Bill moved to an apartment in the same city, and provided his local post office with a "change of address" form. On the advice of the lawyer they had engaged to represent them in the examination, Bill also wrote a letter to the IRS dated December 30, 20x5, informing the Service of his new address together with the other required information. The Revenue Agent conducting the examination for 20x3 and 20x4 asked for a copy of their 20x5 return. The lawyer gave the Agent a copy of Mary's 20x5 return, and informed the Agent that Bill had not filed. Shortly thereafter, the IRS sent Bill a letter saying that it had prepared a return for him based on payee information it had received (W-2s and 1099s). Except for a personal exemption, the return did not include any deductions. The report of the Revenue Agent addressed to Bill and Mary proposed deficiencies in tax for 20x3 and 20x4 of $10,000 and $12,000, respectively. The Revenue Agent issued a separate report for 20x5, addressed to Bill, proposing a deficiency in the amount of $20,000. The lawyer filed protests for all three years, and argued the cases before the Appeals Office. Unfortunately, however, the Appeals Officer to whom the cases had been assigned decided against Bill and Mary on all issues. The IRS sent a Notice of Deficiency to Bill and Mary for 20x3 and 20x4 dated February 1, 20x7, addressed to the home that was still occupied by Mary. Mary sent Bill a copy. 11. Assume that the Tax Court issued its decision on June 1, 20x9. a. How long did Bill and Mary have to decide whether to appeal? b. When does the decision of the Tax Court become final? c. When can the IRS make an assessment against Bill and Mary for 20x3 and 20x4? d. To which Court of Appeals would the decision be appealed?