San Francisco Wesco Polymers, Inc. - Page 3




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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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