- 12 - 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 listedPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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