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other action taken by the taxpayer, written or oral, will operate
to terminate Form 872-A. See Rev. Proc. 79-22, sec. 4.02, 1979-1
C.B. 563, 563; see also Grunwald v. Commissioner, 86 T.C. 85, 89
(1986). Accordingly, we find and hold that respondent timely
issued the notice of deficiency to petitioners within the
applicable period of limitations provided by section 6501(a),
given that the Greenfields executed the Form 872-A extending the
limitations period and that the extension remained in effect when
respondent issued the notice of deficiency to them.
C. Interest
Petitioners argue that waiver of the period of limitations
in Form 872-A applies only to tax, which petitioners view as
exclusive of interest and penalties. In making this argument,
petitioners rely on the literal language of Form 872-A, which, as
petitioners rightly point out, references Federal tax but neither
interest nor penalties. Respondent argues that Form 872-A
constitutes a waiver that extends the period of limitations on
the assessment of tax, interest, penalties, and additions to tax.
This Court has held that use of the term “tax” in Form 872-A
includes penalties and interest. See Pleasanton Gravel Co. v.
Commissioner, 85 T.C. 839, 855 (1985) (citing Picard v.
Commissioner, 28 T.C. 955, 961 (1957)). Neither respondent nor
the Greenfields in any way modified Form 872-A so as to except it
from the law construing the word “tax” on Form 872-A to include
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