Court of Appeals for the Third Circuit June 2, 1982, 81-2459, 81-2460 (Patrick James Ryan v. Commissioner of Internal Revenue)

OPINION OF THE COURT

GIBBONS, Circuit Judge:

Appellant Patrick James Ryan is an individual taxpayer who has filed his federal income tax returns based on a calendar year. On March 1, 1977, the Commissioner of Internal Revenue (hereinafter Commissioner) invoked 26 U.S.C. § 6851(a) which authorizes, under certain circumstances, a termination of an individual’s taxable year.