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Sometime during October 1980, a representative of
respondent's Manhattan District Office forwarded a Special
Consent to Extend the Time to Assess Tax (Form 872-A) to
petitioner and his ex-wife requesting that they extend the period
of limitations for the taxable year 1977 for an unlimited period.
Petitioner and his ex-wife executed the Form 872-A on October 17,
1980, and mailed it to respondent in a preaddressed envelope
provided for that purpose. The Form 872-A was received by
respondent's Manhattan District Office on November 3, 1980, and
signed by a representative of that office on November 4, 1980.
The printed provisions that were part of the form executed by
petitioner and his ex-wife provided, inter alia, that their 1977
taxes could be assessed by respondent at any time prior to 90
days following:
1. The receipt of a Notice of Termination of Special
Consent to Extend the Time to Assess Tax (Form 872-T) by the
Internal Revenue Service office considering the taxpayers' case;
2. the sending of such a notice of termination, Form 872-T,
by the Internal Revenue Service to the taxpayers; or
3. the sending of a statutory notice of deficiency to the
taxpayers for such period (plus the time that assessment of the
deficiency was prohibited by law), plus 60 days.
Thereafter, in January 1981, a representative of
respondent's Newark District Office contacted petitioner and
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