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expired on April 15, 1999.
The regular 3-year period of limitations for assessment of
unemployment tax reportable on Form 940, i.e., FUTA tax, for the
calendar year 1994, expired on January 31, 1998. Prior to that
date, however, both petitioner and respondent executed Form SS-
10, agreeing to extend the period of limitations to July 31,
1998. Prior to this second date, however, both petitioner and
respondent executed Form SS-10, agreeing to extend the period of
limitations to April 15, 1999.
The regular 3-year period of limitations for assessment of
unemployment tax reportable on Form 940 for the calendar year
1995, expired on January 31, 1999.
On December 14, 1998, prior to the expiration of the
foregoing periods of limitations, one of respondent’s authorized
officials signed the Offer in Compromise that petitioner had
submitted earlier that month with respect to (inter alia)
petitioner’s employment tax liabilities for the calendar quarters
in, and the calendar years of, 1994 and 1995. This action by
respondent’s authorized official served to suspend the running of
the period of limitations on assessment of petitioner’s
employment tax liabilities that were covered by the offer. As
applicable herein, such suspension extended from December 14,
1998, through May 13, 1999; i.e., the date on which respondent
rejected the offer, and for 1 thereafter.
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