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The sole issue for decision is whether Form 872, Consent to
Extend the Time to Assess Tax, signed by a duly authorized
officer of SFWP's corporate successor in interest, constitutes a
binding agreement to extend the period of limitations under
section 6501(c)(4) with respect to SFWP's June 30, 1993 taxable
year.
When the petition was filed, SFWP did not have a principal
place of business because it had previously ceased operations.
The IRS office to which SFWP's tax returns were made is located
in Fresno, California. See sec. 7482(b)(1)(B).
Background
The background facts related below are taken from the record
and the undisputed written representations of the respective
parties.
SFWP mailed its Form 1120, U.S. Corporation Income Tax
Return, for the fiscal year ended June 30, 1993 (1993 return) to
the Fresno Service Center on February 2, 1994. SFWP's 1993
return was signed by Miguel Chang (Chang), president and a
director of SFWP. Respondent received SFWP's 1993 return on
February 4, 1994. The general 3-year period of limitations for
assessment of tax expired on February 4, 1997.
SFWP's Employer Identification Number (EIN) is 94-3100328.
The address for SFWP as set forth on its 1993 return was 555
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Last modified: May 25, 2011