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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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