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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.
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Last modified: May 25, 2011