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          a filing date of November 21, 1981.  The differing dates are not             
          material for purposes of this issue.                                         
               On November 20, 1984, IRA and respondent executed a written             
          agreement on Form 872-A, Special Consent to Extend the Time to               
          Assess Tax, to extend the period of limitations on respondent's              
          assessment and collection of IRA's income taxes for 1980.  This              
          Form 872-A has generally been referred to as an "open-ended"                 
          consent because it extends the period of limitations indefinitely            
          until either the taxpayer or the IRS issues to the other a Form              
          872-T to effect a termination of the extension.  If the taxpayer             
          issues the Form 872-T, the extension continues for a period of 90            
          days, within which the IRS must issue a notice of deficiency to              
          the taxpayer.  Neither IRA nor the IRS issued a Form 872-T.  On              
          June 2, 1992, respondent issued the notice of deficiency to IRA              
          for its 1980 tax year.                                                       
               In its petition, IRA affirmatively alleged that the period              
          of limitations barred respondent's assessment and collection of a            
          deficiency and additions to tax against it for 1980.                         
               In the answer, respondent affirmatively alleged that the                
          applicable period of limitations on assessment and collection                
          against IRA for 1980 had not expired at the time the notice of               
          deficiency was issued because respondent and IRA had executed a              
          written agreement extending the period of limitations                        
          indefinitely until the onset of one of the conditions stated                 
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