Ross M. Muir - Page 6

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            extension as contemplated by the statute".  Stenclik v.                                    
            Commissioner, 907 F.2d 25, 27 (2d Cir. 1990), affg. T.C. Memo.                             
                  The Form 872-A extension, although of indefinite duration                            
            when executed, by its terms provides specific procedures for its                           
            termination.  In a Court-reviewed opinion, we held that extension                          
            agreements that contain specific termination provisions do not                             
            expire by operation of law after a reasonable time.  See Estate                            
            of Camara v. Commissioner, 91 T.C. 957, 962 (1988) (issuance of                            
            notices of deficiency terminated Form 872-A agreements executed                            
            more than 5 years earlier).  Rather, such agreements terminate                             
            only by the express provisions of the agreement.  See, e.g.,                               
            Silverman v. Commissioner, 86 F.3d 260, 261-262 (1st Cir. 1996),                           
            affg. 105 T.C. 157 (1995); Bilski v. Commissioner, 69 F.3d 64, 68                          
            (5th Cir. 1995), affg. T.C. Memo. 1994-55; Feldman v.                                      
            Commissioner, 20 F.3d 1128, 1133 (11th Cir. 1994), affg. T.C.                              
            Memo. 1993-17; St. John v. United States, 951 F.2d 232, 235 (9th                           
            Cir. 1991); Stenclik v. Commissioner, supra at 28; Wall v.                                 

                        (4) Extension by agreement.--Where, before the                                 
                  expiration of the time prescribed in this section for                                
                  the assessment of any tax imposed by this title * * *                                
                  both the Secretary and the taxpayer have consented in                                
                  writing to its assessment after such time, the tax may                               
                  be assessed at any time prior to the expiration of the                               
                  period agreed upon.  The period so agreed upon may be                                
                  extended by subsequent agreements in writing made                                    
                  before the expiration of the period previously agreed                                

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