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intent was proper, finding the evidence clear and convincing to
support such action. The evidence consisted of the facts that
"Solar Equipment, Inc. EIN: 43-1156196" was the only subject
under examination and the only issue still open under a prior
written extension.
In this case, we assume that Chang read and understood
respondent's June 20, 1996, letter stating that the attached
Forms 872 related to examination of SFWP's corporate tax return.
Although the Forms 872 listed USAWP's name and EIN, it listed the
taxable year ended June 30, 1993, as the period to be extended.
USAWP filed its first corporate tax return on February 10, 1995,
covering the fiscal year beginning September 1, 1993, and ending
June 30, 1994. Since USAWP's first filed tax return was for the
period ended June 30, 1994, the Form 872's reference to the tax
return ended June 30, 1993, must have referred to SFWP, not
USAWP. Since Chang was the president of both SFWP and USAWP, we
infer that he knew this fact. Therefore, we conclude that Chang
signed the Form 872 with the intent to extend the period of
limitations for SFWP's taxable year ended June 30, 1993. The
evidence clearly and convincingly supports reformation. See also
Buchine v. Commissioner, 20 F.3d 173 (5th Cir. 1994), affg. T.C.
Memo. 1992-36.
SFWP argues that Woods v. Commissioner, supra, does not
authorize reformation where both parties to a reformation have
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