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Tom, a calendar year taxpayer, filed his 2001 Federal income tax return on April 1, 2002. In 2006, the IRS audits this return and assesses

Tom, a calendar year taxpayer, filed his 2001 Federal income tax return on April 1, 2002. In 2006, the IRS audits this return and assesses an income tax deficiency against Tom. On the grounds that the statute of limitations has run, Tom disputes the assessment. Is Tom correct? Why

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