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Recall the facts of Commissioner v. Lundy, 516 U. 235 (1996), and Borenstein v. Commissioner, 149 T. 263 (2017), reversed 919 F.3d 746 (2d Cir. 2019)....

Recall the facts of Commissioner v. Lundy, 516 U.S. 235 (1996), and Borenstein

v. Commissioner, 149 T.C. 263 (2017), reversed 919 F.3d 746 (2d Cir. 2019).

(i) Consider the flush language at the end of section 6512(b)(3) Congress enacted in

response to Lundy. What minimal change to this language would have extricated

Mrs. Borenstein from the predicament she found herself in?

(ii) Now, consider another taxpayer in exactly the same situation as Mrs. Borenstein

with the sole exception that her notice of deficiency was mailed a year and a day later

than Mrs. Borenstein's, viz, on June 20, 2016. How precisely should the flush

language at the end of section 6512(b)(3) have been drafted to help this taxpayer?

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