- 13 - material fact and that petitioner is entitled to partial summary judgment as a matter of law. The chain of consents to extend the statutory period of limitations was broken. Thus, we hold that the period of limitations for 1985 and 1986 expired, at the latest, on December 31, 1992 (the date of extension on the Form 872 signed in 1991). Since the notice of deficiency was mailed to petitioners on September 19, 1994, the statutory period of limitations has expired for each of the tax years 1985 and 1986, unless the underpayment of tax was due to fraud. To reflect the foregoing, An order granting petitioner's motion for partial summary judgment will be issued.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011