Legal Opinion

Grunwald v. Commissioner

United States Tax Court

Decided January 28, 1986No. Docket No. 18984-84PublishedCited by 48 opinions

Petitioners and respondent executed a "Special Consent to Extend the Time to Assess Tax" (Form 872-A) for the taxable years 1975, 1976, 1977, 1978, and 1979. The agreement provided in part that the period of limitation for assessment of income taxes was extended to a date not more than 90 days after "(a) the Internal Revenue Service office considering the case receives Form 872-T, Notice of Termination of Special Consent to Extend the Time to Assess Tax, from the…

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Petitioners and respondent executed a "Special Consent to Extend the Time to Assess Tax" (Form 872-A) for the taxable years 1975, 1976, 1977, 1978, and 1979. The agreement provided in part that the period of limitation for assessment of income taxes was extended to a date not more than 90 days after "(a) the Internal Revenue Service office considering the case receives Form 872-T, Notice of Termination of Special Consent to Extend the Time to Assess Tax, from the taxpayer(s); or (b) the Internal Revenue Service mails Form 872-T to the taxpayer(s); or (c) the Internal Revenue Service mails a…

1Opinion of the Court

OPINION

NlMS, Judge:

This matter is before the Court on respondent’s motion for partial summary judgment pursuant to Rule 121.1 Petitioners have filed a notice of objection to respondent’s motion for partial summary judgment and a cross-motion for partial summary judgment.

Respondent determined deficiencies in petitioners’ Federal income tax as follows:

Year Deficiency

1975 . $29,069.64

1976 . 49,565.30

1977 . 22,164.88

1978 . 24,339.28

1980 . 51,501.32

Respondent’s motion for partial summary judgment and petitioners’ cross-motion for partial summary judgment raise the single issue of whether a letter…

2Cases cited8 opinions

  1. Piarulle v. Comm'rUnited States Tax Court · 1983
  2. Pursell v. CommissionerUnited States Tax Court · 1962
  3. McManus v. CommissionerUnited States Tax Court · 1975
  4. Tallal v. CommissionerUnited States Tax Court · 1981
  5. E. H. Winn, Jr. And Betty Lee Jones Winn v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1979

3 more not listed; retrieve them via the Exa API.

3Cited by48 opinions

  1. Mecom v. CommissionerUnited States Tax Court · 1993
  2. Roszkos v. CommissionerUnited States Tax Court · 1986
  3. Swiss Colony, Inc. v. CommissionerUnited States Tax Court · 1969
  4. DeSantis v. United StatesDistrict Court, S.D. New York · 1992
  5. Estate of Camara v. CommissionerUnited States Tax Court · 1988

43 more not listed; retrieve them via the Exa API.

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