- 9 - the tax returns Mr. Jones gave her to sign during 1981 because, at that time, she trusted him. Upon audit of the Joneses’ 1981 return, the Internal Revenue Service (Service) proposed disallowing the Schedule C loss claimed by the Joneses with respect to the art tax shelter and allowing only their cash outlay as a deduction. On August 20, 1984, the Joneses agreed to the assessment of additional tax for 1981 resulting from disallowance of the Schedule C loss with respect to the art tax shelter by signing Form 1902-B, Report of Individual Income Tax Examination Changes. The Joneses made an advance payment of $610.52 on the art tax shelter adjustment on August 22, 1984, that covered the additional tax as originally proposed plus interest. On September 29, 1984, and March 1, 1985, respectively, the Joneses and a representative of the Service also executed a Closing Agreement on Final Determination Covering Specific Matters concerning only the art tax shelter for which the Joneses had claimed deductions for 1980, 1981, and 1982. On April 25, 1985, the Joneses and a representative of the Service executed a Form 872-A, Special Consent to Extend the Time to Assess Tax, extending the period of limitation for assessment with respect to their 1981 year. The Form 872-A provided that the Service could assess additional tax with respect to the 1981 taxable year at any time subject only to certain limitations.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011