- 3 -
1982, respectively. On each return, petitioner claimed a
substantial loss from his investment in a limited partnership,
relating to, among other things, enhanced oil recovery
technology.
On March 22 and 26, 1984, petitioner and respondent,
respectively, executed a Form 872-A, Special Consent to Extend
the Time to Assess Tax, related to the taxable year ended
December 31, 1980.
On its face, Form 872-A states that the tax due for the
specified year:
MAY BE ASSESSED ON OR BEFORE THE 90TH (NINETIETH) DAY
AFTER: (A) THE INTERNAL REVENUE SERVICE OFFICE
CONSIDERING THE CASE RECEIVES FORM 872-T, NOTICE OF
TERMINATION OF SPECIAL CONSENT TO EXTEND THE TIME TO
ASSESS TAX, FROM THE TAXPAYER(S), OR (B) THE INTERNAL
REVENUE SERVICE MAILS FORM 872-T TO THE TAXPAYER(S), OR
(C) THE INTERNAL REVENUE SERVICE MAILS A NOTICE OF
DEFICIENCY FOR SUCH PERIOD(S), EXCEPT THAT IF A NOTICE
OF DEFICIENCY IS SENT TO THE TAXPAYER(S), THE TIME FOR
ASSESSING THE TAX FOR THE PERIOD(S) STATED IN THE
NOTICE OF DEFICIENCY WILL END 60 DAYS AFTER THE PERIOD
DURING WHICH THE MAKING OF AN ASSESSMENT WAS
PROHIBITED. * * *
On October 7 and 9, 1985, petitioner and respondent,
respectively, executed a Form 872-A related to the taxable year
ended December 31, 1981. That Form 872-A contained the language
quoted above with respect to termination of the extension
agreement.
On January 19, 1988, respondent issued a notice of
deficiency to petitioner. At no time before respondent's
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