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Time to Assess Tax Attributable to Items of a Partnership, with
respect to Foam's 1982 tax year.16 Petitioners concede that this
consent extended the period of limitations for assessment of
partnership items for all partners of Foam to June 30, 1987.
Prior to June 30, 1987, petitioners executed extensions of
time for assessment (the Consents) with respect to their 1982 tax
years.17 Cohn (or on Cohn's behalf his authorized
representative, Bernard L. Dikman (Dikman), C.P.A.) executed a
series of 3 Forms 872, Consent to Extend the Time to Assess Tax.
The first was executed on February 26, 1986, and extended the
limitations period until June 30, 1987. The second was executed
on March 6, 1987, and extended the limitations period until
December 31, 1988. The third was executed on February 12, 1988,
and extended the limitations period until December 31, 1989.
Addington and the Sanns executed Forms 872-A, Special
Consent to Extend the Time to Assess Tax, on December 22, 1985
and March 13, 1986, respectively. Each of the Forms 872-A
extended the period of limitations until the 90th day after (1)
the IRS office considering the case received a Form 872-T, Notice
of Termination of Special Consent to Extend the Time to Assess
Tax, from the taxpayer; (2) the IRS mailed a Form 872-T to the
16 A member of Freedman & Co., Jacobson had been named an
attorney-in-fact for Foam Recycling, along with Freedman, in a
Form 2848, Power and Declaration of Representative, executed by
Roberts on Apr. 2, 1984.
17 The records in these cases indicate, and the parties do not
dispute, that petitioners timely executed their respective
Consents in accordance with sec. 6501(c)(4).
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