Wiley L. Barron, CPA, Ltd. - Page 15




                                       - 14 -                                         
          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.                                   






Page:  Previous  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  Next

Last modified: May 25, 2011