State Police Association of Massachusetts - Page 16

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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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