- 35 - 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).Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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