T.C. Memo. 2004-100
UNITED STATES TAX COURT
JOHN A. ROBERTS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7316-02L. Filed April 9, 2004.
P timely petitioned this Court to review R’s
determination to proceed with collection of assessments
against P for 1982, 1987, and 1988. P alleges that
extensions of the sec. 6502(a)(1), I.R.C., period of
limitations on collection of those assessments were
improperly obtained and are, therefore, invalid. P
further alleges that the extension covering 1982 is
untimely as applied to a 1983 assessment for that year
because it was executed after the sec. 6502(a)(1),
I.R.C., period of limitations on collection with
respect to that assessment had expired.
1. Held: Pursuant to the presumption of official
regularity, the extensions are deemed to be validly
obtained.
2. Held, further: The determination by R’s
Appeals officer that the extension covering 1982 was
timely with respect to a 1983 assessment is supported
by the evidence.
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