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(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.
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