- 13 - section 7436(d)(1), provides that the issuance of a notice of determination serves to suspend the running of the period of limitations on assessment for the period during which the Commissioner is prohibited from making the assessment, and for 60 days thereafter. The period during which the Commissioner is prohibited from making the assessment begins on the date on which the notice of determination is issued and, if an action for redetermination of employment status is commenced, ends on the date on which the decision of this Court becomes final. See sections 6213(a) and 7481, as applicable to the present action by virtue of section 7436(d)(1). We now apply these principles to the taxable periods in issue. A. 1994 and 1995 The regular 3-year period of limitations for assessment of employment taxes reportable on Form 941; i.e., FICA taxes, for the calendar quarters ended March 31, June 30, September 30, and December 31, 1994, expired on April 15, 1998. Prior to that date, however, both petitioner and respondent executed Form SS-10 (Consent to Extend the Time to Assess Employment Taxes), agreeing to extend the period of limitations to April 15, 1999. The regular 3-year period of limitations for assessment of employment taxes reportable on Form 941 for the calendar quarters ended March 31, June 30, September 30, and December 31, 1995,Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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