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pursuant to section 39 to 1981 and 1983 in the respective amounts
of $5,663,086 and $11,454,565, resulting in Alumax' receipt of
tax refunds in those amounts pursuant to section 6411.
The consolidated return filed by Amax for each of the years
1984, 1985, and 1986 constituted the return of each member of
petitioners’ group for each such year, regardless whether the
inclusion of petitioners in each of those consolidated returns
was proper. The respective periods of limitations on the assess-
ment of tax against petitioners’ group for each of the years
1984, 1985, and 1986 began to run on the date on which Amax filed
the consolidated return for each such year.
Respondent commenced an examination of the consolidated
returns that Amax filed for 1984, 1985, and 1986. Prior to the
expiration of the time prescribed by section 6501 for the assess-
ment of income tax due for each of those years from the corpora-
tions that were included, whether properly or improperly, in
those consolidated returns (Amax consolidated group), Amax and
respondent executed the following 11 separate written agreements
on Forms 872 (Consent to Extend the Time to Assess Tax) to extend
the period of time during which any such assessment could be made
by respondent:
Date through
which Period of Date Signed by
Taxable Year(s) to whichLimitations WasDate Signed by Of-Representative
Form 872 Applied Extended ficer of Amax of Respondent
1984 Dec. 31, 1988 Dec. 24, 1987 Mar. 3, 1988
1983 through 1985 Dec. 31, 1989 Aug. 1, 1988 Aug. 15, 1988
1983 through 1985 June 30, 1990 June 20, 1989 July 5, 1989
1984 June 30, 1991 Undated Mar. 30, 1990
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