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On December 17, 1985, respondent received, via certified
mail, the above Form 872 signed by petitioners and dated
December 12, 1985. On December 30, 1985, respondent's authorized
representative signed this Form 872.
On September 9, 1986, more than 3 months before the
December 31, 1986, expiration date, respondent mailed the notice
of deficiency with regard to petitioners' 1982 Federal income
tax.
OPINION
Section 6501(a) provides the general 3-year period of
limitations applicable to respondent's authority to assess
Federal income taxes. Under section 6501(c)(4), before the 3-
year period of limitations has expired, respondent's
representatives and a taxpayer may consent in writing to the
assessment of tax after the expiration of the 3-year period. The
tax may then be assessed at any time before the new expiration
date.
Petitioners and respondent's representative signed the Form
872 on December 12, 1985, agreeing to extend the period of
limitation applicable to petitioners' 1982 Federal income tax to
December 31, 1986. Sec. 6501(c)(4).
Petitioners allege that they did not personally sign the
Form 872 and that someone in respondent's office forged their
signatures.
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Last modified: May 25, 2011