Michael A. Lacher and Judith W. Lacher - Page 10




                                        - 10 -                                          
          York, New York 10022" (the Becker address).  Stuart Becker & Co.              
          was also listed as the preparer of petitioners’ 1981 Federal                  
          income tax return.  Between early 1985 and the middle of 1987,                
          respondent mailed to petitioners a series of Forms 872, Consent               
          to Extend the Time to Assess Tax, requesting that petitioners                 
          extend the period of limitations for 1981.  The Forms 872 were                
          mailed by respondent to the Becker address.  On March 12, 1985,               
          May 8, 1986, and May 14, 1987, petitioner signed the Forms 872                
          and returned them to respondent.  At trial, petitioner initially              
          testified that he did not remember whether he signed any Forms                
          872 or whether Becker represented him when the Forms 872 were                 
          sent to him.  During cross-examination, respondent introduced                 
          copies of the signed Forms 872.  In response, petitioner stated:              
          “My memory may be faulty as to what these things meant or whether             
          and when I got them * * *, [but] my signature is my signature, I              
          did what I did.”                                                              
          Piggyback Agreements                                                          
               On December 19, 1991, respondent sent to petitioners a                   
          proposed Stipulation of Settlement (piggyback agreement) that                 
          would have enabled petitioners to have their case bound to the                
          results reached in Provizer v. Commissioner, T.C. Memo. 1992-177.             
          Petitioners did not agree to the piggyback agreement at this                  
          time.  On March 25, 1992, this Court issued an opinion in the                 
          Provizer case.  Respondent again offered the piggyback agreement              






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