Robert E. Wadlow and Connie V. Wadlow - Page 14




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          specifically, section 6501(c)(4) provides that, where the                   
          Internal Revenue Service (IRS) and the taxpayer have consented in           
          writing, the assessment period is extended.  The accompanying               
          regulations state that the extension of the assessment period               
          "[becomes] effective when the agreement has been executed by both           
          parties."  Sec. 301.6501(c)-1(d), Proced. & Admin. Regs.                    








               1(...continued)                                                        
               section, the amount of any tax imposed by this title shall             
               be assessed within 3 years after the return was filed                  
               (whether or not such return was filed on or after the date             
               prescribed) or, if the tax is payable by stamp, at any time            
               after such tax became due and before the expiration of 3               
               years after the date on which any part of such tax was paid,           
               and no proceeding in court without assessment for the                  
               collection of such tax shall be begun after the expiration             
               of such period.                                                        
                           *    *    *    *    *    *    *                            
                    (c) Exceptions.--                                                 
                           *    *    *    *    *    *    *                            
                         (4) Extension by agreement.--Where, before the               
                    expiration of the time prescribed in this section for             
                    the assessment of any tax imposed by this title, except           
                    the estate tax provided in chapter 11, both the                   
                    Secretary and the taxpayer have consented in writing to           
                    its assessment after such time, the tax may be assessed           
                    at any time prior to the expiration of the period                 
                    agreed upon.  The period so agreed upon may be extended           
                    by subsequent agreements in writing made before the               
                    expiration of the period previously agreed upon.                  




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