John Sann and Marianne Sann, et al. - Page 35

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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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