- 13 - (1976). We conclude that petitioners are liable for the addition to tax under section 6651(a) for failure to timely file their 1994 income tax return. C. Whether the Time To Assess Tax Against Petitioners for 1994 Has Expired Petitioner contends that the time to assess tax against petitioners for 1994 expired before respondent issued the notice of deficiency. We disagree. Collins concedes that the time to assess tax for petitioners’ 1994 tax year has not expired. On June 2, 1999, petitioner signed a Form 872, in which he agreed to extend the time to assess tax for 1994 until October 31, 2000. Respondent issued the notice of deficiency on April 24, 2000. Petitioner does not contend that the Form 872 that he signed is invalid. We conclude that the time to assess the tax for petitioners’ 1994 tax year had not expired when respondent issued the notice of deficiency. To reflect the foregoing, Decisions will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
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