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requested that he and his ex-wife sign a Consent to Extend the
Time to Assess Tax (Form 872) for the taxable year 1977.
Petitioner explained that he had previously submitted a Form
872-A for that year; however, respondent's representative
indicated that the Form 872-A was "probably lost in the mail" as
there was no record of it in the Newark District Office.
Respondent's representative further indicated that a notice of
deficiency would be issued unless petitioner and his ex-wife
agreed to sign the Form 872 extending the time to assess tax to
December 31, 1982. Petitioner and his ex-wife signed the Form
872 and mailed it to respondent's Newark District Office, where
it was signed by respondent's representative on February 13,
1981.
Upon subsequent requests made by respondent, petitioner and
his ex-wife signed two further consents on Forms 872 which were
received and duly countersigned by a representative of
respondent's Newark District Office:
1. In June 1982, extending the period of limitations for
1977 to December 31, 1983; and
2. in February 1983, extending the period of limitations
for 1977 to June 30, 1984.
Respondent returned to petitioner a fully executed copy of
the three Forms 872 within a reasonable time after respondent's
representative countersigned each of these three consent forms.
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