Gary A. and Frances Bybee - Page 4

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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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