Grunwald v. Commissioner
United States Tax Court
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
- Piarulle v. Comm'rUnited States Tax Court · 1983
- Pursell v. CommissionerUnited States Tax Court · 1962
- McManus v. CommissionerUnited States Tax Court · 1975
- Tallal v. CommissionerUnited States Tax Court · 1981
- 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
- Mecom v. CommissionerUnited States Tax Court · 1993
- Roszkos v. CommissionerUnited States Tax Court · 1986
- Swiss Colony, Inc. v. CommissionerUnited States Tax Court · 1969
- DeSantis v. United StatesDistrict Court, S.D. New York · 1992
- Estate of Camara v. CommissionerUnited States Tax Court · 1988
43 more not listed; retrieve them via the Exa API.