- -4 Kim's joint return for the year 1989 to petitioner's authorized representative, Mr. Zuehls. On November 23, 1992, Mr. Zuehls sent to Agent Novella by telephone transmission a copy of the Form 872 bearing what purported to be the signatures of petitioner and Mr. Kim. On November 24, 1992, respondent received by mail the original Form 872. On November 25, 1992, IRS group manager Ms. Sandra Sturla (Ms. Sturla) signed the Form 872 consenting to an extension of time to assess petitioner's tax for the year 1989 on behalf of respondent. At no time prior to the mailing of the notice of deficiency on December 28, 1993, did petitioner inform Agent Novella that she contended that the signature on the Form 872 was not genuine or that she did not consider the Form 872 valid. Respondent determined in her notice of deficiency dated December 28, 1993, that petitioner and Mr. Kim had underreported income and overstated depreciation on their Schedule C and had failed to report gain from the sale of business property. Petitioner contends that the Form 872 does not extend the period of limitation to assess tax for 1989 because petitioner did not sign the form. Respondent's position is that she reasonably relied on the Form 872 and petitioner's agent, Mr. Zuehls, and, therefore, the period of limitations for the year 1989 was properly extended.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011