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Petitioner and respondent by their authorized
representatives executed a Consent to Extend the Time to Assess
Tax (Form 872) on August 3, 1992. The first page of the Form
872 stated, in pertinent part, as follows:
State Police Assoc. of Massachusetts
(Name(s))
taxpayer(s) of 388 Hillside Ave. Needham, Ma. 02194
(Number, Street, City or Town, State, ZIP Code)
and the District Director of Internal Revenue or Regional Director of Appeals
consent and agree to the following:
(1) The amount of any Federal Income Excise[2] tax due on any
(Kind of Tax)
return(s) made by or for the above taxpayer(s) for the period(s) ended
April 30, 1986, 1987, 1988, 1989 and July 31, 1989
may be assessed at any time on or before April 30, 1993 . However, if
(Expiration Date)
a notice of deficiency in tax for any such period(s) is sent to the
taxpayer(s) on or before that date, then the time for assessing the tax will
be further extended by the number of days the assessment was previously
prohibited, plus 60 days.
The only returns filed by petitioner for the periods ended
April 30, 1986 through 1989, and July 31, 1989, were Returns of
Organization Exempt from Income Tax (Form 990).
OPINION
Jurisdiction
The first issue we must decide is whether the period of
limitations on assessment had expired with respect to certain of
2 Petitioner's representative modified the executed Form 872
by deleting the reference to excise tax. A group manager in the
exempt organizations portion of the EPEO division of the Brooklyn
District executed petitioner's modified Form 872 on behalf of
respondent on Aug. 3, 1992.
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