- 7 -
Commissioner, 875 F.2d 812, 813 (10th Cir. 1989); Mulder v.
United States, 37 Fed. Cl. 60, 62 (1996), affd. without published
opinion 132 F.3d 52 (Fed. Cir. 1997); Estate of Camara v.
Commissioner, supra.
Finally, under the Form 872-A procedure, the length of the
extension is irrelevant since it is necessarily acquiesced in by
the taxpayer who does not file the Form 872-T to bring the
extension period to a close. See Stenclik v. Commissioner,
supra. In this case, it is undisputed that petitioner never sent
a Form 872-T to respondent to terminate the agreement.
In accordance with the reasoning set forth in Estate of
Camara v. Commissioner, supra, we hold that assessment of
petitioner's taxes due for 1980 and 1981 is not barred by the
statute of limitations.
To reflect the foregoing,
Decision will be entered for
respondent.
Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011