Leon S. Malachinski v. Commissioner of Internal Revenue
Court of Appeals for the Seventh Circuit
1Opinion of the Court
RIPPLE, Circuit Judge.
The Internal Revenue Service determined that Leon Malachinski was deficient in the payment of his federal income taxes for the year 1980. Dr. Malachinski contested the assessment in the United States Tax Court. He contended (1) that his signature on a consent form to extend the statute of limitations on assessment had been forged and (2) that if any deficiency were assessed, he was entitled to credit against it the $20,400 he previously had remitted to the IRS in 1984. The tax court ruled in favor of the IRS; it found that Dr. Malachinski’s signature on the consent form…
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