Walter R. Ripley, Donee-Transferee of Mildred M. Ripley, Donor, and Melynda H. Ripley, Donee-Transferee of Mildred M. Ripley, Donor - Page 11

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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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