- 577 - 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 statedPage: Previous 567 568 569 570 571 572 573 574 575 576 577 578 579 580 581 582 583 584 585 586 Next
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