Whether the court below, in conflict with its own precedents as well as those of this Court and five other Circuit Courts of Appeal, erred in holding that Petitioners' timely-filed tax return (which the IRS examined, processed, and later relied upon to issue a late-mailed notice of deficiency) did not start the running of the 3-year statute of limitations on assessment.

Whether, in conflict with the Fifth Circuit, the court below erred in finding an informal notice of intent to appeal ineffective to preserve the right of a party's counsel to appeal a sua sponte sanction against him that appears in the Decision.

Whether the court below erred in holding that Petitioners' timely-filed tax return did not start the running of the 3-year statute of limitations on assessment