- 3 - 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 555Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011