- 4 - 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.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011