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Petitioner used a price list in its solicitation program for
The Constabulary. BWE and McKnight set the prices for the
various sized displays and listings with petitioner's approval.
Petitioner's president, Kevin W. Regan, sent letters advising
recipients that petitioner was "selling advertising in the next
edition of The Constabulary yearbook". In its letter, petitioner
set forth its price list for different sizes of "advertisements."
Petitioner advised prospective advertisers that the "prices" for
advertisements in The Constabulary were as follows:
Display Advertisements
Full page $995
3/4 page 850
l/2 page 595
1/3 page 450
l/4 page 395
l/6 page 295
Directory Advertisements
Large bordered $195
Small bordered 135
3-line listing 95
2-line listing 55
Period of Limitations
By letter dated May 21, 1992, petitioner's representative
agreed to execute on behalf of petitioner a Consent to Extend the
Time to Assess Tax (Form 872) to allow the assessment of
additional Federal income tax to occur on or before December 31,
1992, for the periods ended April 30, 1986 through 1989, and July
31, 1989.
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