- 2 - Held: R has established by clear and convincing evidence that C signed Form 872 with the intent to extend the period of limitations for SF's taxable year ended June 30, 1993. Held, further, Form 872 may be reformed to conform with the intent of the parties. Woods v. Commissioner, 92 T.C. 776 (1989), applied. Held, further, R's notice of deficiency is not barred as untimely under the period of limitations on assessments contained in sec. 6501(a), I.R.C. Donald L. Feurzeig, for petitioner. Laurel M. Robinson, for respondent. MEMORANDUM OPINION NIMS, Judge: This matter is before the Court on petitioner's motion for partial summary judgment under Rule 121. Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Respondent determined the following deficiencies and accuracy-related penalties with respect to the Federal income tax of petitioner San Francisco Wesco Polymers, Inc. (SFWP) for the taxable years ending June 30, 1993 and June 30, 1994: Penalties Year Deficiency Sec. 6662(a) June 30, 1993 $108,986 $6,150 June 30, 1994 21,797 1,230Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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