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1985 June 30, 1991 Undated Mar. 30, 1990
1986 June 30, 1991 Undated Mar. 30, 1990
1983 through 1986 June 30, 1992 Undated May 6, 1991
1983 through 1986 Dec. 31, 1992 Undated Jan. 24, 1992
1983 through 1986 June 30, 1993 Aug. 31, 1992 Sept. 3, 1992
1983 through 1986 Dec. 31, 1993 Jan. 28, 1993 Jan. 29, 1993
1983 through 1986 Dec. 31, 1994 Sept. 14, 1993 Sept. 15, 1993
Each of the above-listed Forms 872 identified the "tax-
payer(s)" as "Amax Inc. and Consolidated Subsidiaries" or "Amax
Inc. and Consolidated Subs" and stated in pertinent part that the
taxpayers so identified and a designated representative of
respondent "consent and agree to the following:"
(1) The amount of any Federal [income] tax due on
any return(s) made by or for the above taxpayer(s) for
the period(s) ended [December 31, 1983, December 31,
1984, December 31, 1985, and/or December 31, 1986] may
be assessed at any time on or before [one of the dates
stated on the Form 872 and listed above]. * * *
After the merger of Amax into Cyprus Minerals Company on or
around November 15, 1993, and before the expiration of the time
prescribed by section 6501 for the assessment of income tax due
for 1984, 1985, and 1986 from the corporations in the Amax
consolidated group, Cyprus Amax, the surviving company of that
merger and the successor to Amax, and respondent executed a
written agreement on Form 872 to extend the period of time
through June 30, 1995, during which any such assessment could be
made by respondent. That Form 872 identified the "taxpayer(s)"
as "Amax, Inc. and Consolidated Subsidiaries" and stated in
pertinent part that the taxpayers so identified and a designated
representative of respondent "consent and agree" that the "amount
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