Ross M. Muir - Page 7

                                                - 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                     

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