- 3 -
through 1991 to determine whether it was appropriate to include
petitioner within the Hibiscus consolidated group. Hibiscus and
petitioner have consistently argued throughout the examination
period and in these proceedings that petitioner was properly
included in the Hibiscus consolidated group during the years in
issue.
Forms 872
In February 1992, during the course of the examination,
Revenue Agent Barrett requested that Hibiscus and petitioner
execute separate Forms 872, Consent to Extend the Time to Assess
Tax, for the taxable year 1988. However, petitioner's
representatives refused to execute a separate Form 872 out of
concern that respondent might attempt to use the document as
evidence that petitioner should not be included in the Hibiscus
consolidated group. Instead, Hibiscus' representatives executed
a series of Forms 872 that served to extend the period of
assessment for the years in issue to December 31, 1996. Each of
the Forms 872 in question identifies the taxpayer as "Hibiscus
Life Insurance Co. and Subsidiary". The following schedule shows
the taxable year, the date executed, and the expiration date for
each of the Forms 872 executed on behalf of Hibiscus:
Year Date Executed Expiration Date
1988 1/27/92 9/30/93
1988-89 7/1/93 6/30/94
1988-90 11/11/93 12/31/94
1988-90 11/1/94 12/31/95
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