- 5 - Petitioners herein have completely failed to satisfy their burden to prove that the signatures on the Form 872 constitute forgeries. Rule 142(a). The handwriting reflected by petitioners' signatures on their 1982, 1983, and 1984 joint Federal income tax returns appears to be identical to the handwriting reflected by petitioners' signatures on the Form 872, and no credible evidence indicates to the contrary. In this case, the evidence is clear that the period of limitation to assess tax for 1982 was properly extended to December 31, 1986, and that respondent, on September 9, 1986, timely mailed the notice of deficiency regarding petitioners' 1982 Federal income tax. In accordance with our prior decision and the decision of the Court of Appeals for the Ninth Circuit, we conclude that respondent's notice of deficiency for 1982 was issued within the prescribed statutory period and that petitioners are liable for the Federal income tax deficiency and additions to tax for 1982 as previously determined by this Court in Bybee v. Commissioner, supra. Decision will be entered for respondent.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011