- 3 -
FINDINGS OF FACT
On April 15, 1983, petitioners filed their 1982 joint
Federal income tax return.
In December of 1984, respondent began an audit of
petitioners' 1983 joint Federal income tax return.
In 1985, respondent expanded the audit to include
petitioners' 1982 and 1984 joint Federal income tax returns.
Petitioner refused to provide to respondent's revenue agent any
records relating to 1982 or 1984.
On September 26 and 27, 1985, respondent's revenue agent
requested of petitioner an extension of the period of limitation
on assessment of tax for 1982, which period was due to expire on
April 15, 1986.
On November 19, 1985, petitioner met with respondent's
revenue agent and with the revenue agent's group manager to
discuss the audit generally and the requested extension of the
period of limitation for 1982. During the meeting, the revenue
agent prepared a Form 872, Consent to Extend the Time to Assess
Tax, with regard to petitioners' joint Federal income tax for
1982, reflecting a limitation date of December 31, 1986.
Respondent's revenue agent provided this form to petitioner with
a request to sign the form and to return it to respondent by
December 20, 1985.
Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011