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any such period(s) is sent to the taxpayer(s) on or
before that date, then the time for assessing the tax
shall be further extended by the number of days the
assessment was previously prohibited, plus 60 days.
(2) This agreement ends on the earlier of the above
expiration date or the assessment date of an increase in the
above tax that reflects the final determination of tax and
the final administrative appeals consideration. * * *
Petitioners argue first that the expiration date under paragraph
(1) is April 26, 1992. Starting from the February 25, 1992,
stipulated decision, they add 60 days from the last sentence of
paragraph (1). They contend that the donor's waiver of the
prohibition against assessment under section 6213(a) terminated
the suspension of the limitations period. The addition of this
60 days brings the last day of the limitations period to April
26, 1992. With the addition of the 68-day tacking period, the
last day of the limitations period is brought to July 4, 1992.
Paragraph (2), however, provides that the limitations period
expired on the earlier of the paragraph (1) expiration date, July
4, 1992, as figured above, or "the assessment date * * * that
reflects the final determination of tax and the final
administrative appeals consideration." Petitioners reason that
the latter date is April 7, 1992, the date the IRS made the
assessment based on the stipulated decision entered by this
Court. Because the earlier of July 4, 1992, and April 7, 1992,
is April 7, 1992, petitioners argue that the limitations period
for assessment against the donor expired on April 7, 1992, and
that the 1-year extension of the limitations period against
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