Kronish v. Commissioner
United States Tax Court
While F, P's attorney, was away on vacation, P signed a Form 872, entitled "Consent to Extend the Time to Assess Tax," that purported to extend the period of limitations on assessment with respect to P's taxable year 1978. At the time P signed the form, she believed that the form's terms conformed with the terms F desired. In fact, the form's terms did not conform with the terms F desired.
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While F, P's attorney, was away on vacation, P signed a Form 872, entitled "Consent to Extend the Time to Assess Tax," that purported to extend the period of limitations on assessment with respect to P's taxable year 1978. At the time P signed the form, she believed that the form's terms conformed with the terms F desired. In fact, the form's terms did not conform with the terms F desired. Subsequently, R sought to have P sign another Form 872 with respect to P's taxable year 1978. The second Form 872 contained the same terms as the first Form 872, except that it purported to further extend…
1Opinion of the Court
WELLS, Judge:
Respondent determined a deficiency in petitioner’s Federal income tax for the taxable year 1978 in the amount of $5,532. The issue presented for decision is whether the period for assessing a deficiency against petitioner for her 1978 taxable year expired prior to the date on. which respondent issued a statutory notice of deficiency with respect to such taxable year. The parties agree that our determination with respect to this issue will be dispositive of this case, since petitioner does not challenge respondent’s substantive grounds for disallowing a $20,000 deduction claimed…
2Cases cited19 opinions
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- Estate of Emerson v. CommissionerUnited States Tax Court · 1977
- Samuel Pollack and Annie Pollack v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1968
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- Schulman v. CommissionerUnited States Tax Court · 1989
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