T.C. Memo. 1999-146
UNITED STATES TAX COURT
SAN FRANCISCO WESCO POLYMERS, INC., Petitioner
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7750-98. Filed April 30, 1999.
SF, a dissolved corporation, moved for partial summary
judgment on the ground that the period of limitations under
sec. 6501(a), I.R.C., had expired with respect to SF's
taxable year ended June 30, 1993. SF was liquidated on Dec.
31, 1994, and USA, a corporation, was formed to take over
SF's operations. USA's first corporate tax return was filed
for the taxable year ended June 30, 1994. R mailed a letter
with attached Forms 872, Consent to Extend the Time to
Assess Tax, on June 20, 1996 to C, SF and USA's president,
to extend the time to assess tax with regard to SF's taxable
year ended June 30, 1993. The letter stated that the
attached Forms 872 related to SF's taxable year ended June
30, 1993. The Forms 872 listed USA's name and employer
identification number but listed the taxable year ended June
30, 1993, as the period to be extended. C signed Form 872
in his capacity as president of USA. R mailed a notice of
deficiency on Feb. 3, 1998, more than 3 years after SF's tax
return for the year ended June 30, 1993 was filed.
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