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that we must resort to extrinsic facts to interpret the parties’
intent, we would reject petitioners’ interpretation because it is
inconsistent with the very purpose that the parties must have had
in mind when they executed the Form 872-A. The Joneses signed
the closing agreement with respect to the art tax shelter in
September 1984, and the Service approved it in March 1985. The
Form 872-A was signed by the Joneses on April 1, 1985, and the
Service signed it on April 25, 1985. The obvious purpose for
signing a Form 872-A is to extend the period during which the
Service is permitted to send a notice of deficiency to the
taxpayer. However, the Joneses had already entered into a
closing agreement with the Service covering the art tax shelter
adjustment, and the signing of a Form 872-A therefore would have
been a useless act as to that adjustment. As the parties had
agreed to the liability arising out of the art shelter adjustment
by executing a closing agreement, the Service could have
immediately assessed the tax on that adjustment. Consequently,
the only logical purpose that could have been served by entering
into the extension agreement would have been to allow the Service
to audit other items on the Joneses’ 1981 return and determine
whether any additional tax might be due, e.g., from disallowance
of other deductions claimed on the return. If the Joneses had
merely wanted to keep the assessment period open for the art
shelter adjustment, they could have signed a limited or
restricted Form 872-A limiting the extension to the art tax
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