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to their personal income tax for 1995-98, and that they do not
remember whether they signed any of the others. Respondent’s
forensic document examiner, James T. Puckett (Mr. Puckett),
opined: (1) Mrs. King signed the six Forms 872 in question; (2)
Mr. King signed four of the six Forms 872; and (3) Mr. King
probably signed a fifth Form 872. He expressed no opinion
regarding who signed one of the Forms 872. Petitioners testified
that all the signatures on the Forms 872 look like their
signatures. We conclude that both petitioners signed all eight
of the Forms 872.
2. Dates Petitioners Signed the Forms 872
Petitioners point out that one or both of their signatures
were not dated on the following three Forms 872:
Undated Prior Signed by Current
Signature Years Expiration Respondent Expiration
Mr. King 1996 Dec. 31, 2000 Dec. 6, 2000 Dec. 31, 2001
1997 Apr. 15, 2001
Petitioners 1995-98 Apr. 15, 2002 Mar. 19, 2002 Dec. 31, 2002
Mrs. King 1996-98 Apr. 15, 2002 Mar. 19, 2002 Dec. 31, 2002
Petitioners contend that these Forms 872 are invalid because
some of the signatures are undated. We disagree. A Form 872
need not be dated if it was signed by both parties before the
time to assess tax expired. Sec. 6501(c)(4); Rutter v.
Commissioner, T.C. Memo. 1986-407; sec. 301.6501(c)-1(d), Proced.
& Admin. Regs. Petitioners signed the three Forms 872 listed
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