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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